Case Digest (G.R. No. 101083)
Facts:
Juan Antonio, Anna Rosario and Jose Alfonso Oposa, et al. v. The Honorable Fulgencio S. Factoran, Jr., G.R. No. 101083. July 30, 1993, the Supreme Court En Banc, Davide, Jr., J., writing for the Court.The petitioners were a group of minors represented by their parents (principal plaintiffs) and the Philippine Ecological Network, Inc. (PENI); they filed Civil Case No. 90-777 in the Regional Trial Court (RTC), Makati, Branch 66, against Fulgencio S. Factoran, Jr., then Secretary of the Department of Environment and Natural Resources (DENR) (later substituted by Secretary Angel C. Alcala). Also named as respondent was the presiding judge, Eriberto U. Rosario. The complaint was styled as a taxpayers class suit under Section 12, Rule 3, and alleged that the petitioners (as taxpayers, citizens and representatives of their generation and generations yet unborn) had the right to a balanced and healthful ecology and sought to prevent the alleged continued misappropriation and impairment of the country’s remaining rainforests.
The complaint sought, among other reliefs, an order (1) cancelling all existing timber license agreements (TLAs) and (2) enjoining the DENR from receiving, processing, renewing or approving new TLAs. It alleged extensive factual and expert-based claims of deforestation, dramatic reductions in forest cover, and attendant ecological harms, and asserted that the petitioners had exhausted administrative remedies (including a demand to cancel TLAs). The plaintiffs argued that DENR’s granting and continuing of TLAs amounted to a misappropriation of natural resources and a violation of constitutional and statutory environmental policy.
On 22 June 1990, Secretary Factoran filed a motion to dismiss contending that the complaint stated no cause of action and presented a non-justiciable political question. On 18 July 1991, the RTC granted the motion to dismiss, holding the complaint vague and conclusory, raising a political question properly addressed to the political branches, and that granting the requested reliefs would improperly impair contracts. The plaintiffs then filed a special civil action for certiorari under Rule 65 of the Revised Rules of Court, asserting that the trial court gravely abused its discretion.
This Court gave due course to the petition on 14 May 1992, ordered memoranda after the Office of the Solicitor General filed a comment, and ultimately resolved the merits. The Supreme Court set aside the RTC’s dismissal for grave abuse of discretion, held that...(Pro-only)
Issues:
- Do the petitioners have locus standi and may they maintain Civil Case No. 90-777 as a class suit, including minors suing for succeeding generations?
- Did the trial court gravely abuse its discretion in dismissing the complaint for failure to state a cause of action and for presenting a political question?
- Are timber license agreements (TLAs) contracts protected by the constitutional non-impairment of contracts clause so as to bar their cancellation or inhibit...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)