Case Summary (G.R. No. 101083)
Petition and Prayer
Petitioners brought a taxpayers’ class suit seeking (1) cancellation of all existing timber license agreements (TLAs) and (2) a cease-and-desist order against processing or approving new TLAs. They invoked their right to a balanced and healthful ecology and intergenerational justice, alleging the State’s failure to protect vital forest resources.
Factual Allegations
The complaint traced forest cover decline from roughly 16 million hectares (53% of land area) in the 1960s to about 850,000 hectares of old-growth rainforest by 1990. It linked this deforestation to water shortages, salinization of aquifers, massive soil erosion, biodiversity loss, cultural displacement of indigenous communities, siltation of rivers and dams, droughts, intensified typhoons, flooding of lowlands, and contributions to global warming.
Cause of Action and Legal Basis
Petitioners asserted that the DENR Secretary’s issuance and renewal of TLAs constituted misappropriation or impairment of natural resources held in trust. They claimed a clear constitutional right to a balanced ecology (Art. II, § 16) and a correlative State duty under Civil Code Articles 19–21, EO 192 § 4, PD 1151, and parens patriae theory.
Procedural History and Dismissal
On June 22, 1990, the DENR Secretary moved to dismiss for lack of cause of action and for presenting a non-justiciable political question. The Makati RTC granted the motion on July 18, 1991, finding the complaint vague, raising political issues, and suggesting relief would impair contracts. Petitioners then filed a Rule 65 certiorari before the Supreme Court.
Constitutional and Statutory Framework
The Court reviewed the newly constitutionalized right to a balanced and healthful ecology (Art. II, § 16) alongside the right to health (Art. II, § 15). It examined EO 192’s mandate for DENR to ensure sustainable resource use and the Administrative Code’s parallel policy. PD 1151 (1977) reinforced the intergenerational environmental stewardship principle.
Locus Standi and Class Suit
The Supreme Court upheld the action as a valid class suit under Rule 3, § 12, finding the subject matter common to all Filipinos and impracticable to join individually. It recognized minors’ standing to represent present and future generations in defending the ecological right.
Merits: Right to a Balanced and Healthful Ecology
Admitting petitioners’ allegations as hypothetically true for a motion-to-dismiss analysis, the Court found a specific fundamental right at issue. The complaint adequately alleged denial of the constitutional right to a healthful ecology and the DENR Secretary’s correlative duty, establishing a prima facie cause of action.
Abuse of Discretion and Political Question Doctrine
The Court rejected the political question defense, emphasizing its constitutional duty (Art. VIII, § 1) to
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Background and Parties
- Petitioners are numerous minors, each represented by their parents, joined by the Philippine Ecological Network, Inc. (PENI)
- They filed Civil Case No. 90-777 in RTC Makati, Branch 66, as a taxpayers’ class suit
- Defendants are the Secretary of the DENR (originally Factoran, subsequently Alcala) and the RTC judge
Factual Allegations
- Philippine archipelago: 7,100 islands, 30 million hectares land area; original rainforest cover some 16 million ha (53%)
- Satellite and survey data show reduction to 1.2 million ha in 1987 (4%), further down to 850,000 ha of old-growth (2.8%) and 3.0 million ha of secondary growth
- Government granted Timber License Agreements (TLAs) covering 3.89 million ha for commercial logging
- Current deforestation rate ~200,000 ha/year (≈25 ha/hour), forecasting complete forest loss within the decade
- Adverse environmental impacts already manifest: drying aquifers and watercourses; salinization; massive soil erosion; loss of flora, fauna, and indigenous cultures; siltation of rivers and dams; increased flooding, droughts, and typhoon intensity; contribution to global warming
Cause of Action and Prayer for Relief
- Plaintiffs assert constitutional right to a balanced and healthful ecology, parens patriae protection for minors and unborn generations
- Claim misappropriation/impairment of natural resources held in trust by DENR
- Administrative demand of March 1–2, 1990 to cancel all TLAs went unheeded
- Prayer:
- Cancel all existing TLAs nationwide
- Cease and desist from receiving, processing, renewing, or approving new TLAs
- Grant other just and equitable reliefs
Procedural History
- 22 June 1990: DENR Secretary’s Motion to Dismiss (no cause of action; political question)
- 12 July 1990: Petitioners’ Opposition—clear cause, no political question
- 18 July 1991: RTC Order granting Motion to Dismiss on grounds of lack of cause, political question, and