LOCUS STANDI

G.R. No. 180771, April 21, 2015

RESIDENT MARINE MAMMALS OF THE PROTECTED SEASCAPE TANON STRAIT, E.G., TOOTHED
WHALES, DOLPHINS, PORPOISES, AND OTHER CETACEAN SPECIES, JOINED IN AND
REPRESENTED HEREIN BY HUMAN BEINGS GLORIA ESTENZO RAMOS AND ROSE-LIZA EISMAOSORIO, IN THEIR CAPACITY AS LEGAL GUARDIANS OF THE LESSER LIFE-FORMS AND AS
RESPONSIBLE STEWARDS OF GOD'S CREATIONS, Petitioners, v. SECRETARY ANGELO REYES, et.al

Facts: Protesting the adverse ecological impact of JAPEX's oil exploration activities in the Taon Strait, petitioners Resident
Marine Mammals and Stewards aver that a study made after the seismic survey showed that the fish catch was reduced
drastically by 50 to 70 percent. They claim that before the seismic survey, the average harvest per day would be from 15 to
20 kilos; but after the activity, the fisherfolk could only catch an average of 1 to 2 kilos a day. They attribute this "reduced fish
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catch" to the destruction of the "payao" also known as the "fish aggregating device" or "artificial reef." Petitioners Resident
Marine Mammals and Stewards also impute the incidences of "fish kill"
seismic survey.

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observed by some of the local fisherfolk to the

Issue: WON Resident Mammals has locus Standi

Held: In Oposa, we allowed the suit to be brought in the name of generations yet unborn "based on the
concept of intergenerational responsibility insofar as the right to a balanced and healthful ecology is
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concerned." Furthermore, we said that the right to a balanced and healthful ecology, a right that does not
even need to be stated in our Constitution as it is assumed to exist from the inception of humankind, carries
with it the correlative duty to refrain from impairing the environment.

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In light of the foregoing, the need to give the Resident Marine Mammals legal standing has been eliminated
by our Rules, which allow any Filipino citizen, as a steward of nature, to bring a suit to enforce our
environmental laws. It is worth noting here that the Stewards are joined as real parties in the Petition and
not just in representation of the named cetacean species. The Stewards, Ramos and Eisma-Osorio, having
shown in their petition that there may be possible violations of laws concerning the habitat of the Resident
Marine Mammals, are therefore declared to possess the legal standing to file this petition.
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