Doctrine of presumed-identity approach
The doctrine of processual presumption is also known as the doctrine of presumed-identity approach in International Law.Accordingly, the International Law doctrine of presumed-identity approachor processual presumption comes into play, i.e., where a foreign law is not pleaded or, evenif pleaded, is not proven, the presumption is that foreign law is the same as Philippine Law.
Under Philippine Law, the phrase "Yung Sam Kang ‘married to' Hyun Sook Jung" is merely descriptive of the civil status of Kang. In other words, the import from the certificates of title is that Kang is the owner of the properties as they are registered in his name alone, and that he is married to Hyun Sook Jung. (Orion Savings Bank vs. Suzuki; G.R. No. 205487, November 12, 2014)