Villar, Emmanuel Dominic L.

LM1A
CASE DIGEST
Oposa v. Factoran, G.R. No. 101083, 30 July 1993

FACTS:
The plaintiff claims that the negative and harmful effects of ongoing deforestation can be
demonstrated beyond a reasonable doubt to the point where they can be brought up as a matter for
judicial notice. Throughout the trial, they stated that they intended to introduce expert witnesses in
addition to photogenic, video, and documentary evidence. Secretary Factoran, Jr. filed a move to
dismiss the complaint on June 22, 1990. On July 18, 1991, the respondent judge granted the motion
to dismiss, upholding the defendants’ earlier claim.
ISSUE:
• Whether or not the plaintiff sufficiently specified whether it was alleging a specific legal
right or wrong.
• Whether or not the petitioners are able to speak for both the current and future generations.
HELD:
• No, the petitioners did not neglect to raise any legal rights or wrongs; rather, the complaint
centers on a single legal right: the right to a healthy and balanced ecosystem, which is
formally recognized by the fundamental law.
• Yes, insofar as the right to a balanced and healthy ecology is concerned, the petitioners'
assertion of that right also constitutes the performance of their obligation to ensure the
protection of that right for future generations. The petition is based on the concept of
integrational responsibility. The petitioners can file a case suit on behalf of themselves and
future generations.
Wherefore, being impressed with merit, the instant petition is hereby granted, and the challenged
order of respondent Judge of 18 July 1991 dismissing Civil Case No. 90-777 is hereby set aside.
The petitioners may therefore amend their complaint to implead as defendants the holders or
grantees of the questioned timber license agreements.
No pronouncement as to costs.
Resident Marine v. Sec. Reyes, G.R. No. 180771, 21 April 2015

FACTS:
The human petitioners represent themselves as the legal guardians of the lesser life forms, and the
petitioners, resident marine mammals, allegedly bring their case in their personal capacity,
claiming that they stand to gain or suffer from the decision on the issues. By claiming they can
speak for animals, the petitioners hope to establish both procedural and substantive rights for them.
They also want the court to acknowledge, by way of judicial notice, that they have a guardianship
relationship with all the resident mammals in the impacted ecology.
ISSUE:
Whether or not can residents of Tañon Strait marine mammals be represented by human
petitioners?
HELD:
No, for the human petitioners to be regarded as representing the Residents Marine Mammals, they
must demonstrate that the Residents Marine Mammals are a real party in interest and that the
human petitioners are permitted by law or the Rules to act in that capacity. In this instance, it is
determined that the Residents Marine Mammals are a real party in interest and have legal rights,
but the human petitioners were unable to provide sufficient evidence to support their claims. The
court, through its analysis, suggests that a qualified organization that has demonstrated
commitment to a cause could bring suit on behalf of the speechless in the form of court-sanctioned
guardianship. are permitted by law or the rules to act as a representative.
Wherefore, the petitions in G.R. Nos. 180771 and 181527 are granted, Service Contract No. 46 is
hereby declared null & void for violating the 1987 Constitution, Republic Act No. 7586, and
Presidential Decree No. 1586.