Resident Marine Mammals of the Protected Seascape Tanon Strait

v. Reyes, G.R. Nos. 180771 & 181527, 21 April 2015, 756 SCRA 513

FACTS:
 In 1988, the Tanon Straight was declared a protected seascape.
 On June 2022, the Government of the Philippines, acting through the Department of
Energy, entered into a Geographic Survey and Exploration Contract with Japan
Petroleum Exploration Co. Ltd. (JAPEX) to conduct geographical studies of the
Tanon Straight (GSEC-102)
 On December 2004, the DOE and JAPEX converted the geographic survey (GSEC-
102) into an exploration, development and production of petroleum resources
contract (SC-46)
 On March 2007, the DENR granted an Environmental Compliance Certificate to
JAPEX which allowed it to drill an exploratory well. The drilling lasted until
February 2008
 Thus these petitions collectively referred to as the Resident Marine Mammals since
the impugned party at interest by the petitioners “The Stewards” are the are the
“toothed whales, dolphins, porpoises, and other cetacean species, which inhabit the
waters in and around the Tañon Strait.”
ISSUES:
 Can animals or even inanimate objects, such as the “resident marine mammals” in
this case, have the legal standing to be petitioners in the case at bar?
RATIO:
 The Supreme Court ruled that Service Contract No. 46 (SC-46) be declared null and
void for violation the 1987 Constitution, Republic Act No. 7586, and Presidential
Decree No.
 1586.
 As for the locus standi of the petitioner “resident marine mammals” the Court held
that according to the 1997 Rules of Court it demands that parties to a suit be either
natural or juridical persons, or entities authorized by law. It further necessitates the
action to be brought in the name of the real party-in-interest, even if filed by a
representative.
 The Court held that in our jurisdiction, locus standi in environmental cases has been
given a more liberalized approach. The current trend in Philippine legal theory and
jurisprudence is already moving towards simplification of procedures and facilitating
court access in environmental cases.
 The Court gives notice to the passing of the landmark Rules of Procedure for
Environmental Cases, which allow for a "citizen suit," and permit any Filipino
citizen to file an action before our courts for violations of our environmental laws.
The new rules liberalizes standing for all cases filed enforcing environmental laws
and collapses the traditional rule on personal and direct interest, on the principle that
humans are stewards of nature.
 This principle was first laid down in Oposa v. Factoran, when it allowed minors and
generations yet unborn as valid parties with legal standing in cases involving the
environment.
 The Court said that 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.