Mabuhay Holdings Corporation vs. Sembcorp Logistics Limited, G.R. No. 212734, 5 December 2018 (Philippines)

The Supreme Court held that it adopts the majority and narrow approach to determine whether the enforcement of an award is contrary to public policy pursuant to the State's policy, in favor of arbitration and enforcement of arbitral awards. Mere errors in the interpretation of the law or factual findings would not suffice to warrant refusal of enforcement under the public policy ground. The illegality or immorality of the award must reach a certain threshold such that, enforcement of the same would be against the State's fundamental tenets of justice and morality, or would blatantly be injurious to the public or the interests of the society.