Case Summary (G.R. No. 129546)
DENR and Local Objections
From May 1989 onward, DENR field offices documented that the dumpsite lay within a protected watershed, violated PD 705, threatened 1,192 families’ water sources, caused erosion and siltation, and degraded ecological balance. LLDA (Mar. 1990) and DENR‐EMB (Jun. & Jul. 1990) criticized the site’s incompatibility and suspended its ECC upon finding slumping and erosion. San Mateo officials and residents repeatedly petitioned Presidents Ramos and Ramos’s Executive Secretary to rescind or reconsider the landfill’s location.
Environmental Compliance Certificate and Suspension
Under PD 1586, MMDA secured an ECC in Feb. 1990 for 2.5 hectares of landfill operation. Following DENR investigations citing ground slumping, erosion, and failure to mitigate, the EMB suspended the ECC in July 1990 pending revised designs. Subsequent DENR letters (1993) and bureau objections (1995) reaffirmed that the dumpsite contravened watershed reservation purposes.
Presidential Proclamation and Jurisdictional Issues
Despite unanimous agency objections, Executive Secretary Torres issued Proclamation No. 635 (28 Aug. 1995), excluding ~106 ha from the watershed reservation for MMDA landfill use, subject to existing environmental laws and reversion when no longer needed. Petitioners challenged its legality and constitutionality via certiorari, prohibition, and mandamus.
Proceedings in the Court of Appeals
Petitioners sought injunctive relief and annulment of Proclamation No. 635. During preliminary injunction hearings, MMDA lawyers warned closure would proliferate open dumps across Metro Manila. On 13 Jun. 1997, the Court of Appeals dismissed the petition for lack of cause of action, accepting MMDA’s integrated solid‐waste management rationale and buffer‐zone argument.
Issues on Appeal to the Supreme Court
Petitioners contended that: (1) Proclamation No. 635 was founded on a forged DENR recommendation; (2) it relied on a spurious ECC; (3) only Congress may modify a protected area under RA 7586; (4) the CA ignored adverse findings of environmental agencies; (5) the buffer‐zone claim was baseless; and (6) the CA improperly favored Metro Manila’s “mini‐Smokey Mountains” argument over statutory safeguards.
Constitutional and Statutory Framework
Under the 1987 Constitution, all public‐domain lands and natural resources are state‐owned; exploration and utilization fall under DENR’s full control and supervision. The non-impairment clause yields to police power, permitting regulation of contracts in the interest of public health and welfare.
DENR’s Mandate and Environmental Policy
E.O. 192 and the Administrative Code (Title XIV, Book IV) charge DENR with sustainable development, management, and conservation of natural resources—including watershed areas—with authority “subject to law and higher authority.” The State’s policy emphasizes intergenerational responsibility to maintain ecological balance.
Local Government Code Requirements
RA 7160 mandates prior consultation (Sec. 2[c]) and sanggunian approval (Sec. 27) for national projects causing pollution, resource depletion, or ecological imbalance. Municipal officials possess broad powers to protect health, safety, and the environment (Secs. 16, 447). San Mateo’s Sangguniang Bayan consistent
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Facts and Background
- Metro Manila faced a severe garbage disposal crisis in the early 1990s, leading to the selection of a site within the Marikina Watershed Reservation for a sanitary landfill.
- On 17 November 1988, the DPWH, DENR, and MMC entered into an MOA allowing dumpsite development at Pintong Bocaue, San Mateo, Rizal.
- From February 1989 onward, local officials of San Mateo protested the dumpsite by resolutions and letters, citing a municipal ban on Metro Manila dumpsites.
- DENR field units repeatedly reported that the dumpsite lay within the protected watershed, violated forestry laws, caused soil erosion, and threatened over a thousand families’ water supplies.
- On 19 February 1990, the DENR Environmental Management Bureau issued an ECC for the dumpsite, only to suspend it on 31 July 1990 due to ground slumping and erosion.
- LLDA formally objected in March 1990, warning that dumpsites within the watershed would undermine efforts to upgrade Laguna Lake’s water quality.
- Subsequent DENR reports documented bad odors, respiratory illnesses among schoolchildren, swarming flies, windblown debris, and leachate contaminating creeks and downstream water bodies.
- Despite adverse findings from multiple agencies, Proclamation No. 635 (28 August 1995) excluded about 106 hectares of the watershed from protection and placed it under MMDA administration for waste disposal.
Procedural History
- June 1996: Petitioners filed a petition for certiorari, prohibition, and mandamus before the Court of Appeals, seeking to annul Proclamation No. 635 and enjoin landfill operations.
- 14 August 1996: Hearing on the petitioners’ application for a temporary restraining order/writ of preliminary injunction.
- 13 June 1997: The Court of Appeals denied the petition for lack of cause of action.
- 22 July 1996: Petitioners filed before the Supreme Court a petition for review on certiorari.
- 24 January 2001: The Supreme Court issued a te