Which of the following is NOT an instance when a Philippine court may take judicial notice of a foreign law?

• A. Evidently familiar with the foreign law.
• B. When the foreign law refers to the law of nations.
• C. When it refers to a published treatise, periodical or pamphlet on the subject of law if the writer is recognized as an expert.
• D. When the foreign law is cited only in a party's brief without recognition.

Answer: (D)