Title
Oposa vs. Factoran Jr.
Case
G.R. No. 101083
Decision Date
Jul 30, 1993
Minors and PENI sued to halt deforestation, invoking the constitutional right to a balanced ecology and inter-generational responsibility; Supreme Court upheld their standing and cause of action.

Case Summary (G.R. No. 101083)

Key Dates and Procedural History

Complaint filed as a taxpayers class suit (Civil Case No. 90-777). Motion to dismiss by DENR Secretary filed 22 June 1990 on grounds of lack of cause of action and political question. RTC granted the motion and dismissed the complaint by order of 18 July 1991. Petitioners filed a certiorari petition with the Supreme Court; the Supreme Court resolved to give due course and, by decision, set aside the dismissal order.

Reliefs Sought by Petitioners

Petitioners sought, inter alia, (1) cancellation of all existing timber license agreements (TLAs) in the country; (2) an injunction directing the DENR to cease and desist from receiving, accepting, processing, renewing or approving new TLAs; and (3) such other equitable reliefs as the court might deem just.

Factual Allegations in the Complaint

The complaint alleged extensive deforestation and environmental degradation: a drastic reduction from about 16 million hectares of rainforests (roughly 53% of land area 25 years earlier) to approximately 850,000 hectares of virgin old-growth forest and about 3 million hectares of secondary growth; adverse effects including water shortages, salinization, erosion and loss of soil fertility, species endangerment and extinction, displacement of indigenous cultures, siltation of waterways and dams, droughts, increased typhoon velocity, flooding, and contribution to global warming. Plaintiffs asserted that TLAs covering approximately 3.89 million hectares had been granted and that continued logging at current rates would exhaust forest resources imminently.

Alleged Legal Basis and Cause of Action

Petitioners grounded their cause of action on (a) constitutional rights — specifically the right to a balanced and healthful ecology (Section 16, Article II) and the right to health (Section 15, Article II) of the 1987 Constitution; (b) statutory and executive policies (P.D. No. 1151, P.D. No. 1152, E.O. No. 192, Administrative Code of 1987); (c) the DENR’s correlative duty under Section 4 of E.O. No. 192 to conserve, manage and ensure equitable sharing of natural resources for present and future generations; and (d) general principles of intergenerational responsibility and parens patriae protection for minors. The complaint asserted that the DENR’s allowance and renewal of TLAs constituted a misappropriation or impairment of natural resources held in trust for present and future generations and alleged exhaustion of administrative remedies by service of a final demand to cancel logging permits.

Trial Court’s Reasoning for Dismissal

The RTC sustained the DENR Secretary’s motion to dismiss, concluding: (1) the complaint failed to allege with sufficient definiteness a specific legal right or specific legal wrong (invoking Sec. 1, Rule 2, RRC); (2) the pleadings contained vague assumptions and unverified conclusions insufficient to state a cause of action; (3) the subject matter was a political question implicating separation of powers and public policy (thus non-justiciable); and (4) granting the requested relief (canceling TLAs) would impair contracts contrary to the Constitution’s non-impairment clause.

Supreme Court’s Review Standard on Motion to Dismiss

The Supreme Court reiterated the governing principle that on a motion to dismiss for failure to state a cause of action, the court must accept the factual allegations of the complaint as hypothetically true and determine only whether, on those facts, a valid judgment could be rendered in accordance with the prayer. The Court cautioned against premature dismissal where the complaint alleges sufficient facts to constitute a prima facie cause of action.

Class Suit Characterization and Locus Standi

The Supreme Court affirmed that the action was a valid class suit under Section 12, Rule 3 of the Revised Rules of Court: the subject matter is of common and general interest, the class is numerous and impracticable to bring individually, and the named plaintiffs are representative. Importantly, the Court recognized that minors could assert rights on behalf of succeeding generations based on the doctrine of intergenerational responsibility insofar as the right to a balanced and healthful ecology is concerned, thereby validating the petitioners’ locus standi to sue for present and future generations.

Justiciability and Political Question Doctrine

The Court rejected the RTC’s political-question bar. It explained that the complaint did not seek policy formulation but enforcement of rights against policies already articulated in the Constitution and in statutes and executive issuances. The Court emphasized the expanded judicial power under Section 1, Article VIII of the 1987 Constitution, which authorizes courts to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction by any branch or instrumentality of government. Accordingly, even matters with political implications may be reviewed when they present legally demandable and enforceable rights or when grave abuse of discretion is alleged.

Constitutional and Statutory Foundations for Plaintiffs’ Right

The Court identified Section 16, Article II (right to a balanced and healthful ecology) and Section 15, Article II (right to health) of the 1987 Constitution as specific constitutional anchors for petitioners’ claim. It also cited E.O. No. 192 (Section 4 mandate and Section 3 policy), Title XIV of the Administrative Code (Declaration of Policy and DENR mandate), and P.D. Nos. 1151 and 1152 as existing statutory and executive expressions of policy and duties that substantiate the DENR’s correlative obligation to protect natural resources for present and future generations.

Cause of Action Analysis and Prima Facie Finding

Applying the cause-of-action test, the Supreme Court found that the complaint sufficiently alleged: (1) petitioners’ legal right to a balanced and healthful ecology; (2) the DENR’s correlative duty to conserve and regulate natural resources; and (3) acts or omissions of the DENR (granting, continuing, or renewing TLAs) that allegedly violated that duty. The Court held that, on the face of the complaint, petitioners established a prima facie cause of action and therefore dismissal was improper. The Court, however, noted that cancellation of TLAs would require the impleading of TLA holders as indispensable parties.

Timber License Agreements and the Non‑Impairment Clause

The Court addressed the RTC’s concern regarding impairment of contracts. It held that TLAs are licenses or privileges — regulatory instruments by which the State controls disposition and use of forest resources — and are not contracts vested with irrevocable property rights protected under the Constitution’s non-impairment clause. The Court cited precedents holding that timber licenses may be amended, modified, replaced or rescinded when national interest so requires (e.g., P.D. No. 705, Section 20) and that licenses are subject to the police power of the State. Even assuming TLAs were contract-like, the Court observed the present case did not involve an enacted law impairing contracts; and in any event, legitimate exercises of police power for

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