Case Digest (G.R. No. 118295) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Taáda v. Angara (G.R. No. 118295, May 2, 1997), petitioners Senator Wigberto E. Taáda, Senator Anna Dominique Coseteng, Representatives Gregorio Andolana and Joker Arroyo, Nicanor P. Perlas, Horacio R. Morales, and several non-governmental organizations challenged the Philippine Senate’s concurrence in the ratification of the Agreement Establishing the World Trade Organization (WTO Agreement) under the 1987 Constitution. On April 15, 1994, Secretary Rizalino Navarro for the Philippines signed the Final Act of the Uruguay Round in Marrakesh, Morocco, committing to submit the WTO Agreement, related Ministerial Declarations and Decisions, and the Understanding on Commitments in Financial Services for constitutional approval. By letters dated August 11, 1994, President Ramos transmitted these documents to the Senate. On December 14, 1994, Senate Resolution No. 97 concurred in the ratification of the WTO Agreement alone; the President ratified the Agreement on December 16, 1994. P Case Digest (G.R. No. 118295) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Historical and Institutional Background
- Post-World War II Multilateral Trade Architecture
- Plans for three Bretton Woods institutions: IMF, World Bank, ITO; ITO never ratified by U.S., leaving GATT (General Agreement on Tariffs and Trade) as the de facto trade framework.
- Successive GATT negotiating rounds (Kennedy, Tokyo, Uruguay) culminated in the Final Act signed in Marrakesh, Morocco on April 15, 1994, creating the World Trade Organization (WTO).
- Philippine Participation and Executive Submission
- On April 15, 1994, DTI Secretary Rizalino Navarro signed the Final Act on behalf of the Philippines, obliging submission of the WTO Agreement for legislative concurrence and adoption of Ministerial Declarations and Decisions.
- President Ramos, by letters dated August 11, 1994, transmitted to the Senate:
- The Uruguay Round Final Act.
- The Agreement Establishing the WTO, its Annexes (multilateral trade agreements in goods, services and intellectual property), Ministerial Declarations/Decisions, and the Understanding on Commitments in Financial Services.
- On December 9, 1994, the President certified the necessity of immediate Senate action; on December 14, 1994, the Senate adopted Resolution No. 97 concurring in the ratification of the WTO Agreement.
- On December 16, 1994, President Ramos signed the Instrument of Ratification of the WTO Agreement and its Annexes as integral parts of the treaty.
- The Petition and Parties
- Petitioners: A coalition of senators and representatives (TaĂĄda, Coseteng, Andolana, Arroyo, Perlas, Morales) as taxpayers, joined by NGOs representing taxpayers, filed a Rule 65 petition for certiorari, prohibition and mandamus. Their prayer:
- Nullify Senate concurrence in the WTO Agreement for violating Philippine economic-nationalist constitutional provisions.
- Prohibit implementation and enforcement of the WTO Agreement.
- Respondents: The senators who voted for concurrence; Cabinet members and executive officials responsible for WTO ratification and execution.
- Procedural History
- Filing and Due Course
- Petition filed December 29, 1994; Court resolved December 12, 1995 to give due course under Rule 65, citing grave abuse of discretion remedy.
- Documentary Submissions
- Memoranda of petitioners (March 11, 1996) and respondents.
- “Bautista Paper”: profile of WTO and summary of agreements by Ambassador Lilia Bautista (August 1996).
- Senate materials: Committee report, hearing transcripts; Solicitor General’s listings of prior treaties and printed copy of the 36-volume Uruguay Round materials.
- Issue Refinement
- Original seven issues by petitioners, condensed with some defenses (estoppel, locus standi) waived or subsumed.
- Court distilled five principal justiciable questions to resolve.
Issues:
- Jurisdictional Justiciability
- Economic-Nationalist Provisions
- Section 19, Article II (“self-reliant, independent national economy effectively controlled by Filipinos”);
- Sections 10 and 12, Article XII (preference for Filipino-owned enterprises, labor, domestic materials, locally produced goods)?
- Legislative Power
- Judicial Power
- Validity of Senate Concurrence
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)