anada v.

Angara
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 self-reliant 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