CASE NO.

02
Province of Rizal v. Executive Secretary
G.R. No. 129546 December 13, 2005

Facts:

The case involves a petition filed by the Province of Rizal, the municipality of San
Mateo, and various concerned citizens against several government agencies and
officials. The petitioners are challenging the legality and constitutionality of
Proclamation No. 635, which excluded certain parcels of land from the Marikina
Watershed Reservation for use as a sanitary landfill and waste disposal site. The land
in question had been in operation as a landfill since 1990, receiving solid waste from
several cities and municipalities in Metro Manila.

The petitioners argue that the landfill site is located within the Marikina Watershed
Reservation, which is protected by law. They claim that the operation of the landfill
is in violation of environmental laws and regulations, and that it poses a threat to the
health and welfare of the residents of San Mateo and Metro Manila.

Issue:

The main issue in this case is whether Proclamation No. 635, which excluded certain
parcels of land from the Marikina Watershed Reservation for use as a sanitary
landfill and waste disposal site, is legal and constitutional.

Ruling:

The Supreme Court ruled in favor of the petitioners and declared Proclamation No.
635 as unconstitutional. The Court held that the exclusion of the land from the
Marikina Watershed Reservation for the purpose of establishing a landfill was in
violation of environmental laws and regulations. The Court also found that the
operation of the landfill posed a threat to the health and welfare of the residents of
San Mateo and Metro Manila.

Ratio:

The Court based its decision on several grounds. First, it found that the landfill site
was located within the Marikina Watershed Reservation, which is protected by law.
The Court held that the exclusion of the land from the reservation for the purpose of
establishing a landfill was contrary to the purpose of preserving and protecting the
watershed.

Second, the Court found that the operation of the landfill was in violation of
environmental laws and regulations. The Court noted that the landfill had caused soil
erosion, water pollution, and the destruction of the ecosystem in the area. The Court
held that these environmental impacts were unacceptable and could not be justified.
Finally, the Court considered the health and welfare of the residents of San Mateo
and Metro Manila. The Court found that the operation of the landfill posed a threat
to the health and welfare of the residents, as it emitted foul odors, attracted disease-
carrying vectors, and contaminated the water sources in the area. The Court held that
the protection of the health and welfare of the residents should take precedence over
the establishment of a landfill.

In conclusion, the Supreme Court ruled that Proclamation No. 635 was
unconstitutional and ordered the closure of the landfill. The Court emphasized the
importance of preserving and protecting the environment, as well as the health and
welfare of the residents. The decision serves as a reminder that the government has
a duty to uphold and enforce environmental laws and regulations for the benefit of
the people.