The Court has adopted a rule that even where the petitioners have failed to show direct injury,

they
have been allowed to sue under the principle of “transcendental importance.” Pertinent are the
following cases:

(1) Chavez v. Public Estates Authority, where the Court ruled that the enforcement of the constitutional
right to information and the equitable diffusion of natural resources are matters of transcendental
importance which clothe the petitioner with locus standi;

(2) Bagong Alyansang Makabayan v. Zamora, wherein the Court held that “given the transcendental
importance of the issues involved, the Court may relax the standing requirements and allow the suit to
prosper despite the lack of direct injury to the parties seeking judicial review” of the Visiting Forces
Agreement;

(3) Lim v. Executive Secretary, while the Court noted that the petitioners may not file suit in their
capacity as taxpayers absent a showing that “Balikatan 02-01” involves the exercise of Congress’ taxing
or spending powers, it reiterated its ruling in Bagong Alyansang Makabayan v. Zamora, that in cases of
transcendental importance, the cases must be settled promptly and definitely and standing
requirements may be relaxed.

By way of summary, the following rules may be culled from the cases decided by this Court. Taxpayers,
voters, concerned citizens, and legislators may be accorded standing to sue, provided that the following
requirements are met:

1. the cases involve constitutional issues;

2. for taxpayers, there must be a claim of illegal disbursement of public funds or that the tax measure is
unconstitutional;

3. for voters, there must be a showing of obvious interest in the validity of the election law in question;

4. for concerned citizens, there must be a showing that the issues raised are of transcendental
importance which must be settled early; and

5. for legislators, there must be a claim that the official action complained of infringes upon their
prerogatives as legislators.