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Consti Questions and Answers On Feb. 1, 2021
Consti Questions and Answers On Feb. 1, 2021
3rd case
On the issue of petitioner's standing With regard to the issue of whether petitioner may prosecute this
case as the real party-in-interest, the Court adopts the view enunciated in Executive Secretary v.
Court of Appeals,4 to wit: The modern view is that an association has standing to complain of
injuries to its members. This view fuses the legal identity of an association with that of its members.
An association has standing to file suit for its workers despite its lack of direct interest if its members
are affected by the action. An organization has standing to assert the concerns of its constituents.
The rule of pacta sunt servanda, one of the oldest and most fundamental maxims of international law,
requires the parties to a treaty to keep their agreement therein in good faith. The observance of our
country's legal duties under a treaty is also compelled by Section 2, Article II of the Constitution
which provides that "[t]he Philippines renounces war as an instrument of national policy, adopts the
generally accepted principles of international law as part of the law of the land, and adheres to the
policy of peace, equality, justice, freedom, cooperation and amity with nations." Under the doctrine
of incorporation, rules of international law form part of the law of the and land no further legislative
action is needed to make such rules applicable in the domestic sphere (Salonga & Yap, Public
International Law, 1992 ed., p. 12).