G.R. No. 210588 - Purisima vs. Lazatin

On February 17, 2012, Secretary of Finance Purisima, upon recommendation of the Commissioner of Internal Revenue, promulgated Revenue Regulation (RR) No. 2-2012.
RR 2-2012 required the payment of VAT and excise tax on all petroleum and petroleum products imported into the Philippines—including those brought directly into Freeport and Economic Zones (FEZs)—subject to later credit or refund if the importer showed the goods were sold to a registered FEZ locator and used for its registered activity.

On March 7, 2012, Representative Lazatin filed a petition for prohibition and injunction in the Angeles City RTC, arguing that RR 2-2012 contravened RA 9400, which grants Clark FEZ status as a separate customs territory with tax‐ and duty‐free importations.
Ecozone Plastic Enterprises Corporation (EPEC), a Clark FEZ locator, intervened alleging that RR 2-2012 stripped FEZ locators of their tax‐exempt status by requiring advance payment and cumbersome refund procedures.
The RTC issued a TRO and later a writ of preliminary injunction blocking RR 2-2012’s implementation.

The petitioners secured relief from the Court of Appeals, which set aside the RTC’s injunction. Respondents then sought relief in the Supreme Court (G.R. No. 208387) but no injunction was granted.
Meanwhile, Lazatin amended his petition into one for declaratory relief; EPEC’s intervention was affirmed.
On November 8, 2013, the RTC:

Upheld the amendment and intervention as proper;
Found both Lazatin and EPEC had legal standing;
Declared RR 2-2012 unconstitutional for violating RA 9400 and usurping Congress’s exclusive power to enact or amend laws.

Whether Representative Lazatin and EPEC have legal standing to seek declaratory relief.
Whether RR No. 2-2012 is valid and constitutional under RA 9400 and the Constitution.