Case Digest (G.R. No. 209271) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In International Service for the Acquisition of Agri-Biotech Applications, Inc. v. Greenpeace Southeast Asia (Philippines), G.R. No. 209271 et al., decided on July 26, 2016 under the 1987 Constitution, petitioners ISAAA and the University of the Philippines Los Baños Foundation, Inc. (UPLBFI), joined by Crop Life Philippines, the Environmental Management Bureau (EMB) of DENR, the Bureau of Plant Industry (BPI) and the Fertilizer and Pesticide Authority (FPA), sought review of the Court of Appeals’ May 17, 2013 decision and its September 20, 2013 resolution in CA-G.R. SP No. 00013. Respondents Greenpeace Southeast Asia (Philippines), MASIPAG, public figures and scientists filed on April 26, 2012 a Petition for Writ of Continuing Mandamus and Writ of Kalikasan before the Supreme Court, alleging that field trials of genetically modified Bt talong violated their constitutional right to health and a balanced ecology for lack of an Environmental Compliance Certificate, inadequate publ Case Digest (G.R. No. 209271) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Bt talong field trials
- Petitioners UPLB, UPLBFI, ISAAA, and UPMFI conducted contained and field trials (2007–2009 contained; 2010–2012 field) of Bacillus thuringiensis–engineered eggplant (“Bt talong”) under:
- National Committee on Biosafety of the Philippines (NCBP) containment rules (EO 430).
- Two-year Biosafety Permits from the Bureau of Plant Industry (BPI) under DA Administrative Order No. 8-2002 (DAO 08-2002).
- Field tests took place in North Cotabato, Pangasinan, Camarines Sur, Davao City, and Laguna. Petitioners complied with biosafety measures; eggplant materials were destroyed after analysis.
- Petition for Writ of Kalikasan and Procedural History
- On April 26, 2012, respondents Greenpeace, MASIPAG, and others filed a Writ of Continuing Mandamus and Kalikasan, alleging:
- Lack of Environmental Compliance Certificate and public consultations.
- Insufficient independent safety data; invoked the precautionary principle.
- Supreme Court issued the writ; petitioners filed verified returns claiming full compliance and scientific support for Bt talong safety.
- The case was referred to the Court of Appeals (CA), which:
- On May 17, 2013, permanently enjoined field trials, applying the precautionary principle.
- On September 20, 2013, denied motions for reconsideration.
- Petitioners elevated to the Supreme Court; on December 8, 2015, the Court:
- Upheld CA decision, applied the precautionary principle, invalidated DAO 08-2002 for failing to conform with National Biosafety Framework (EO 514) and public participation.
- Enjoined all GMO activities pending a new administrative order.
- Petitioners filed motions for reconsideration, arguing mootness, non-raised validity of DAO 08-2002, and lack of evidence for cited studies.
Issues:
- Mootness and its exceptions
- Whether the petition for Writ of Kalikasan became moot upon expiration of Biosafety Permits and termination of field trials.
- If moot, whether any of the four exceptions (grave constitutional violation; exceptional character & paramount public interest; guiding principle; capable of repetition yet evading review) apply.
- Collateral challenge to DAO 08-2002
- Whether the Supreme Court erred in invalidating DAO 08-2002, which was not directly challenged.
- Impact of new Joint Department Circular No. 1-2016 (JDC 01-2016) superseding DAO 08-2002.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)