Tomoyuki Yamashita vs.

Wilhelm Styer
G.R. No. L-129 December 19, 1945

FACTS:

Petitioner Tomoyuki Yamashita, the commanding general of the 14th army group of the
Japanese Imperial Army in the Philippines, after his surrender became a prisoner of war of the United
States of America but was later removed from such status and placed in confinement as an accused war
criminal charged before an American Military Commission constituted by respondent Lieutenant
General Styer, Commanding General of the United States Army Forces, Western Pacific.

Filing for habeas corpus and prohibition against respondent, he asks that he be reinstated to his
former status as prisoner of war, and that the Military Commission be prohibited from further trying
him. He questions, among others, the jurisdiction of said Military Commission.

ISSUE: Was the Military Commission validly constituted by respondent, therefore having jurisdiction
over the war crimes

HELD:  Yes. Under the laws of war, a military commander has an implied power to appoint and convene
a military commission. This is upon the theory that since the power to create a military commission is an
aspect of waging war, military commanders have that power unless expressly withdrawn from them. By
the Articles of War, and especially Article 15, the Congress of the United States has explicitly provided so
far as it may constitutionally do so, that military tribunals shall have jurisdiction to try offenders or
offenses against the laws of war in appropriate cases.

Resident Marine Mammals of the Protected Seascape Tañon Strait vs. Secretary Angelo Reyes
G.R. No. 180771 April 21, 2015

FACTS:
Two sets of petitioners filed separate cases challenging the legality of Service Contract No. 46
(SC-46) awarded to Japan Petroleum Exploration Co. (JAPEX).   The service contract allowed JAPEX to
conduct oil exploration in the Tañon Strait during which it performed seismic surveys and drilled one
exploration well.  The first petition was brought on behalf of resident marine mammals in the Tañon
Strait by two individuals acting as legal guardians and stewards of the marine mammals.  The second
petition was filed by a non-governmental organization representing the interests of fisherfolk, along
with individual representatives from fishing communities impacted by the oil exploration activities. The
petitioners filed their cases in 2007, shortly after JAPEX began drilling in the strait.  In 2008, JAPEX and
the government of the Philippines mutually terminated the service contract and oil exploration activities
ceased.  The Supreme Court consolidated the cases for the purpose of review.

ISSUE: Whether or not the marine mammals, through their stewards have legal standing to pursue the
case
Yung nasa yellow kahit wag na ilagay lol
HELD: Yes, in our jurisdiction, locus standi in environmental cases has been give a more liberalized
approach. The Rules of Procedure for Environmental Cases allow for a “citizen suit,” and permit any
Filipino citizen to file an action before our courts for violation of our environmental laws on the principle
that humans are stewards of nature. Even before the Rules of Procedure for Environmental cases
became effective, the SC had already taken a permissive position on the issue of locus standi in
environmental cases. In Oposa, the SC allowed the suit to be brought in the name of generations yet
unborn based on he concept of intergenerational responsibility insofar as the right to a balanced and
healthful ecology is concerned.

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 also worth noting 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 the
petition.