G.R. No 101083
Minors of the Philippines vs. DENR
July 30, 1993
Petitioner minors, represented by their parents, contended that the granting of the TLAs (Timber License Agreement) by respondent DENR was done with grave abuse of discretion, violated their constitutional right to a balanced and healthful ecology; hence, the full protection thereof requires that no further TLAs should be renewed or granted. RTC dismissed the class suit on the ff grounds: 1)lack of cause of action; 2)the issue involved a political question and 3)the relief sought would violate the non-impairment of contracts clause.
Whether or not minors had the legal personality to initiate the suit.
Whether or not the case was justiciable.
Whether or not the relief sought would violate the non-impairment of contracts clause
The Court ruled in favor of petitioners.
The petitioners had the locus standi necessary to sustain the bringing and, maintenance of the suit. The Court recognized the beneficiaries’ right of action in the field of environmental protection, citing provisions in the Constitution of the rights of the people specifically that of Sec 16, Art 2, which is the specific legal right invoked by the petitioners. The Court also stressed the correlative duty of the DENR as the branch of government tasked with the conservation, development and utilization of the country’s natural resources (E.O. No. 192 and Administrative Code of 1987). Thus, the right of the petitioners (and all those they represent) to a balanced and healthful ecology is as clear as the DENR’s duty to protect and advance the said right.
As to the issue on political question, the case should be afforded judicial review, citing second paragraph of sec1, Article VIII of the Constitution which states that Judicial power includes the duty of the courts of justice to settle actual controversies involving rights which are legally demandable and enforceable, and to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government. The Court may take cognizance of cases involving issues on ‘grave abuse of discretion’.
The Court also assailed the ruling of the lower court, invoking the non-impairment clause, reasoning, for one, that the respondents did not even raise the said issue. Granting for argument’s sake that respondents did, the TLA is not a contract but is only a license or a privilege which may be subject to withdrawal by proper authority if deemed necessary for the general welfare and betterment of the country.
(side issue: The Court granted the petition, allowing petitioners to amend complaint against TLA holders.)