G.R. No. 125509 - Public Interest Center, Inc. vs. Roxas

On February 9, 1976, respondent National Power Corporation (NPC) entered into a contract with respondent Westinghouse Electric S.A. (WESA) to construct a 620-megawatt nuclear power plant at Morong, Bataan.
WESA later assigned all its rights and responsibilities under the contract to its construction agent, respondent Westinghouse International Projects Company (WIPCO).

In 1986, President Corazon Aquino issued Executive Order (E.O.) No. 55 (later amended by E.O. No. 98), transferring the ownership of the already constructed plant (later known as the Bataan Nuclear Power Plant or BNPP) and all related assets to the National Government.
The National Government assumed all remaining foreign and local obligations incurred by NPC in financing the BNPP construction.

In 1988, legal actions initiated in New Jersey and arbitration proceedings in Geneva were undertaken against Westinghouse regarding the BNPP.
On September 27, 1995, under President Fidel Ramos, a Government Panel was created—with key representatives such as Chief Presidential Legal Counsel Antonio T. Carpio and Solicitor General Raul T. Goco—to explore settlement options with Westinghouse.
President Ramos, on October 4, 1995, issued Executive Order No. 265, establishing the Presidential Committee on the Bataan Nuclear Power Plant (PC-BNPP) as the coordinating body for policy-making and settlement negotiations.
By October 11, 1995, the PC-BNPP Committee adopted a resolution reflecting the essential terms for settlement, which entailed:

A cash payment of $40 million.
The delivery of two 501-F Eco-nopac combustion turbines (totaling 320 MW) valued at $60 million.
Westinghouse’s relinquishment of the recovery of over $200,000 in attorneys’ fees.

On October 13, 1995, the Settlement Agreement was executed reflecting the resolution’s terms between the Republic/NPC and the Westinghouse corporations.

On November 14, 1995, petitioners (Public Interest Center, Inc., Laureano T. Angeles, and Jocelyn P. Celestino) filed a Complaint in the Regional Trial Court (RTC) of Quezon City seeking the nullification of:

During the preliminary proceedings, only petitioners and the Republic/NPC appeared at the hearing scheduled on November 28, 1995, with the absence of any representative from the Westinghouse corporations.
On the same day, the Solicitor General moved to dismiss the complaint on the ground of forum-shopping, alleging that petitioners were involved in similar proceedings in Manila.
A subsequent Amended Complaint (filed on December 4, 1995) broadened the reliefs sought, including the issuance of a preliminary mandatory injunction, the declaration of nullity of the BNPP Contract, associated loan contracts, and the Settlement Agreement, and the recovery of payments and additional costs.
The Republic and NPC responded by filing motions to dismiss on various grounds, including lis pendens, lack of legal capacity, and absence of a cause of action.
On April 17, 1996, the Quezon City RTC dismissed the petitioners’ complaint based on:

Violation of the Anti-Forum Shopping Rule.
Lack of jurisdiction over foreign and international bodies and actions.
The failure to allege issues sufficient to confer standing under the relaxed rule on matters of public interest.

Petitioners’ subsequent motion for reconsideration was denied on June 18, 1996, leading them to elevate the case via a petition for certiorari and mandamus before the Supreme Court.

Whether petitioners, as citizens and taxpayers, possess the requisite personal and substantial interest to invoke judicial protection over the allegedly invalid contracts and settlement agreement.
Whether the assertion of a public or general interest, as opposed to a particularized injury, confers standing in taxpayer suits.

Whether the filing of similar actions in different courts (one in Manila and another in Quezon City) constitutes forum-shopping.
Whether the alleged absence of identity in the parties or causes of action between the two proceedings is sufficient to avoid the consequences of lis pendens or res judicata.

Whether the validity of the BNPP contract, the associated loan agreements, and the Settlement Agreement entered into with Westinghouse are matters subject to judicial review.
Whether courts may set aside or entertain challenges to a settlement concluded with a foreign or international component.

Whether a judgment rendered in an earlier proceeding (involving similar cause of action and issues) can have a res judicata effect upon the subsequent complaint filed by petitioners.