District Court was no longer appealed by petitioner, AIFL, and/or ATHONA.The Order dated March 13, 1990 of the U.S. District Court in Civil ActionNo. H-86-440 is presumptive evidence of the right of respondent todemand from petitioner the payment of US$49,450.00 even in thisjurisdiction. The next question then is whether petitioner was able todischarge the burden of overcoming the presumptive validity of said Order.The Court rules in the negative.In complete disregard of the limited review by Philippine courts offoreign judgments or final orders, petitioner opposes the enforcement ofthe Order dated March 13, 1990 of the U.S. District Court on the very sameallegations, arguments, and evidence presented before and considered bythe U.S. District Court when it rendered its verdict imposing the Rule 11sanction against petitioner. Petitioner attempts to convince the Court thatit is necessary to look into the merits of the Order dated March 13, 1990because the U.S. District Court committed clear mistake of law and fact inissuing the same. The Court, however, is not convinced. A Philippine courtwill not substitute its own interpretation of any provision of the law orrules of procedure of another country, nor review and pronounce its ownjudgment on the sufficiency of evidence presented before a competentcourt of another jurisdiction. Any purported mistake petitioner attributesto the U.S. District Court in the latter’s issuance of the Order dated March13, 1990 would merely constitute an error of judgment in the exercise of itslegitimate jurisdiction, which could have been corrected by a timely appealbefore the U.S. Court of Appeals.Petitioner cannot insist that the RTC and the Court of Appeals resolvethe issue of whether or not petitioner, AIFL, and ATHONA had reasonablegrounds to implead respondent as a counter-defendant in Civil Action No.
12H-86-440. Although petitioner submitted such an issue for resolution bythe RTC in its Pre-Trial Brief, the RTC did not issue any pretrial orderactually adopting the same. In addition, petitioner was also unable to laythe basis, whether in U.S. or Philippine jurisdiction, for the use of the“reasonable grounds standard” for determining a party’s liability for orexemption from the sanctions imposed for violations of Rule 11 of the U.S.Federal Rules of Civil Procedure. Equally baseless is petitioner’s assertionthat the Rule 11 sanction is contrary to public policy and in effect, puts apremium on the right to litigate. It bears to stress that the U.S. DistrictCourt imposed the Rule 11 sanction upon petitioner, AIFL, and ATHONA fortheir frivolous counterclaims against respondent intended to simplyhumiliate and embarrass respondent; and not because petitioner, AIFL, andATHONA impleaded but lost to respondent. Contrary to the claims ofpetitioner, both the RTC and the Court of Appeals carefully considered theallegations, arguments, and evidence presented by petitioner to repel theOrder dated March 13, 1990 of the U.S. District Court in Civil Action No. H-