1. RA 10591 was enacted on May 29, 2013.
It regulated the ownership,
Full Case Title: ERIC F. ACOSTA AND NATHANIEL G. DELA PAZ, PETITIONERS,
v. HON. PAQUITO N. OCHOA, IN HIS CAPACITY AS EXECUTIVE SECRETARY,
HON. MANUEL A. ROXAS III, IN HIS CAPACITY AS SECRETARY OF THE
INTERIOR AND LOCAL GOVERNMENT, POLICE DIRECTOR GENERAL ALAN LM.
PURISIMA, IN HIS CAPACITY AS DIRECTOR GENERAL, PHILIPPINE NATIONAL
POLICE, POLICE CHIEF SUPERINTENDENT MELITO M. MABILIN, IN HIS
CAPACITY AS DIRECTOR, CIVIL SECURITY GROUP, PHILIPPINE NATIONAL
POLICE, AND POLICE CHIEF SUPERINTENDENT LOUIE T. OPPUS, IN HIS
CAPACITY AS CHIEF, FIREARMS AND EXPLOSIVES OFFICE, PHILIPPINE
NATIONAL POLICE, RESPONDENTS. (Consolidated cases)
Date of Promulgation: October 15, 2019
Doctrines:
1. Legal standing is the right of appearance in a court of justice on a
given question. It ensures that the party bringing the case has a
personal and substantial interest in the outcome, since he/she may
sustain direct injury as a result of the controversy.
2. There are exceptions to the rule on legal standing, as found in:
- Funa v Villar (see cases cited, enumerated doon)
- White Light v City of Manila (enumerated din)
- Provincial Bus Operators Association of the Philippines for factors in
considering granting standing to associations and corporations suing
on behalf of its members.
Recit - Ready Summary: Consolidated petitions assailing the constitutionality
of some provisions of RA 10591, or the Comprehensive Firearms and
Ammunition Regulation Act, and some provisions in their IRR for being
violative of petitioners’ right to bear arms, right to property, and right to
privacy (since the law required on one of the forms for firearm registration,
the inspection of the applicant’s house). On the second issue of legal
standing to sue, Acosta, dela Paz and PROGUN were found to have legal
standing to sue, due to the assailed law’s violation or possible violation of
the right against unreasonable searches and seizures.
Facts:
possession, carrying, manufacture, dealing in, and importation of
firearms and ammunition in the country. It was enacted with the view
of maintaining peace and order and protecting the people from
violence.
a. Its IRR was promulgated on December 7, 2013, pursuant to
rule-making power granted to the PNP Chief.
2. After the effectivity of the IRR, the PNP centralized all firearm licensing
and renewals at its HQ in Camp Crame.
a. They also started issuing a pro forma application form for
firearm registration, requiring consent to “Voluntary
Presenation for Inspection”.
3. Licensed firearm owners Acosta and Dela Paz filed before the Supreme
Court a Petition for Prohibition, assailing the constitutionality of RA
10591, specifically:
a. Multiple sections of the law;
b. The requirement of signing the Consent Form for voluntary
inspection of firearms for being violative of the right against
unreasonable searches and seizures, since it allowed the PNP
to inspect a person’s house as a requirement for firearm
registration.
c. This was docketed as G.R. No. 211559, and the subject of this
digest.
4. PROGUN, a registered nonstock, nonprofit corporation that represents
the interests of legitimate and licensed gun owners filed their own
action.
5. Guns and Ammo Dealers Association of the PH also filed a petition.
6. The petitions were consolidated.
Issue/s: 15 total issues. What’s relevant to the topic is the second one:
Whether or not petitioners have legal standing to file their petitions.
Ratio/ Legal Basis: Petitions partly granted.
1. Petitioners Acosta, Dela Paz, and PROGUN were found to have legal
standing to file their suits.
2. The Court first defined legal standing as an aspect of justiciability. It
was defined as: “the right of appearance in a court of justice on a
given question.”
a. Legal standing ensures that the party bringing the case has a
personal and substantial interest in the outcome such that
they have sustained or will sustain direct injury as a result of
its enforcement.
b. The Court qualified this further, emphasizing the essential
nature of a direct injury, because it would guarantee a
personal stake in the outcome of the controversy.
3. The Court further explained that the concept of legal standing is
similar to the concept of “interest” in private/civil suits.
a. The Court referred to interest as a “present substantial
interest”, as distinguished from a “mere expectancy of a
future, contingent, subordinate, or consequential interest”.
b. The Court explained that legal standing / interest is the reason
why under the RoC, actions must be prosecuted or defended
in the name of the real party-in-interest.
4. The Court cited Funa vs. Villar in explaining the exceptions to the rule
on legal standing, that even though a person is not directly injured,
they were nonetheless allowed to file petitions (see cases cited).
5. The Court then cited White Light Corp vs. City of Manila, where the
concept of third-party standing was introduced as another exception
to the rule on direct injury (see cases cited).
6. The Court afterwards cited Provincial Bus Operators Association of the
Philippines to present the factors to be considered in granting standing
to associations and corporations suing on behalf of its members:
a. Actual controversy, and clear demonstration of special
reasons why truly injured parties may not be able to sue.
b. Alternatively, the associations should show their reasons for
bringing the actions themselves rather than as a class suit,
since a subject matter of the controversy may be of general
interest to many persons.
c. A showing of the transcendent nature of the right involved.
7. The Court said that in the present case, petitioners Acosta and Dela
Paz as individual firearms license holders are ones who stand to suffer
direct injury should the inspection of their houses be required for
firearm registration.
8. PROGUN was also found to be sufficiently clothed with legal standing
to bring on behalf of its individual members a suit to question their
possible violation of their constitutional right to unreasonable
searches.
9. However, the other petitions were found to be dismissible for lack of
legal standing on the part of petitioners Guns and Ammo Dealers and
PROGUN.
Disposition: WHEREFORE, the Petitions in G.R. Nos. 212570 and 215634
are DISMISSED.
As for the Petitions in G.R. Nos. 211559 and 211567, they are PARTLY
GRANTED. Section 9.3 of the 2013 Implementing Rules and Regulations of
Republic Act No. 10591 is declared UNCONSTITUTIONAL for being contrary to
Article III, Section 2 of the Constitution. The Philippine National Police
is PROHIBITED from requiring individual applicants either for a license to own
and possess firearm or for a new firearm registration-to sign the Consent of
Voluntary Presentation for Inspection, or otherwise requiring inspection of
their houses as a requirement for a license to own and possess firearm unless,
armed with a search warrant.
This Court's April 8, 2014 Temporary Restraining Order is made PERMANENT.
Finally, petitioner Peaceful Responsible Owners of Guns, Inc.'s Verified Petition
for Contempt is DISMISSED for lack of merit.

Cases cited:
Funa v. Villar: Court enumerated four (4) types of "nontraditional suitors"
who, though not having been directly injured by the assailed governmental
act, were nonetheless allowed to file the petition because they raised issues of
critical significance:

1.) For taxpayers, there must be a claim of illegal disbursement of public funds

or that the tax measure is unconstitutional;
2.) For voters, there must be a showing of obvious interest in the validity of
the election law in question;
3.) For concerned citizens, there must be a showing that the issues raised are
of transcendental importance which must be settled early; and
4.) For legislators, there must be a claim that the official action complained of
infringes their prerogatives as legislators.77 (Emphasis in the original)

White Light Corporation vs. City of Manila: the concept of third-party standing
was introduced in our jurisdiction as another exception to the direct injury
rule. Under this concept, a litigant may file a case on behalf of third parties
when the following criteria concur:
(1) "the litigant must have suffered an 'injury-in-fact,' thus giving him or her a
'sufficiently concrete interest' in the outcome of the issue in dispute";
(2) "the litigant must have a close relation to the third party"; and
(3) "there must exist some hindrance to the third party's ability to protect his
or her own interests."
Laws cited: