Tanada vs Angara 272

SCRA 18
Facts
On April 15, 1994, the Philippine
Government represented by its
Secretary of the Department of
Trade and Industry signed the
Final Act binding the Philippine
Government to submit to its
respective competent authorities
the WTO (World Trade
Organization) Agreements to seek
approval for such. On December
14, 1994, Resolution No. 97 was
adopted by the Philippine Senate
to ratify the WTO Agreement.
This is a petition assailing the
constitutionality of the WTO
agreement as it violates Sec 19,
Article II, providing for the
development of a self reliant and
independent national economy,
and Sections 10 and 12, Article XII,
providing for the Filipino first
policy.
Issue
Whether or not the Resolution No.
97 ratifying the WTO Agreement is
unconstitutional
Ruling
The Supreme Court ruled the
Resolution No. 97 is not
unconstitutional. While the
constitution mandates a bias in
favor of Filipino goods, services,
labor and enterprises, at the same
time, it recognizes the need for
business exchange with the rest of
the world on the bases of equality
and reciprocity and limits
protection of Filipino interests only
against foreign competition and
trade practices that are unfair. In
other words, the Constitution did
not intend to pursue an
isolationalist policy. Furthermore,
the constitutional policy of a selfreliant and independent national
economy does not necessarily rule
out the entry of foreign

investments, goods and services. It

contemplates neither economic
seclusion nor mendicancy in the
international community.
The Senate, after deliberation and
voting, gave its consent to the WTO
Agreement thereby making it a
part of the law of the land. The
Supreme Court gave due respect to
an equal department in
government. It presumes its
actions as regular and done in
good faith unless there is
convincing proof and persuasive
agreements to the contrary. As a
result, the ratification of the WTO
Agreement limits or restricts the
absoluteness of sovereignty. A
treaty engagement is not a mere
obligation but creates a legally
binding obligation on the parties.
A state which has contracted valid
international obligations is bound
to make its legislations such
modifications as may be necessary
to ensure the fulfillment of the
obligations undertaken.