Background

The case arose from the need to update the Philippines' maritime baselines to comply with UNCLOS III. RA 9522 was enacted for this purpose, but it was challenged by the petitioners on constitutional grounds. The case reached the Supreme Court, which had to determine whether the new baselines law was consistent with the Philippine Constitution's definition of national territory.

Facts

• 1. In 1961, Congress passed Republic Act No. 3046 (RA 3046) demarcating the maritime baselines of the Philippines as an archipelagic State.
• 2. In 1968, RA 5446 was enacted to correct typographical errors in RA 3046 and to add a provision asserting Philippine sovereignty over Sabah.
• 3. The Philippines ratified the United Nations Convention on the Law of the Sea (UNCLOS III) on February 27, 1984.
• 4. In March 2009, Congress amended RA 3046 by enacting RA 9522 to align the country's maritime baselines with the requirements of UNCLOS III.

Arguments of the Petitioners

• 1. RA 9522 reduces Philippine maritime territory and the reach of the Philippine state's sovereign power, violating Article 1 of the 1987 Constitution.
• 2. The law opens the country's waters to maritime passage by all vessels, undermining Philippine sovereignty and national security.
• 3. RA 9522 violates the country's nuclear-free policy and risks damaging marine resources.
• 4. The treatment of the Kalayaan Island Group (KIG) as a "regime of islands" results in the loss of a large maritime area.
• 5. The law fails to mention either the Treaty of Paris or Sabah, potentially weakening territorial claims.

Arguments of the Respondents

• 1. RA 9522 is the country's compliance with the terms of UNCLOS III, preserving Philippine territory over the KIG and Scarborough Shoal.
• 2. The law does not undermine the country's security, environment, and economic interests.
• 3. RA 9522 does not relinquish the Philippines' claim over Sabah.
• 4. The baselines law is consistent with the Philippine Constitution and international law.

Issues

• 1. Whether the petitioners possess locus standi to bring this suit.
• 2. Whether the writs of certiorari and prohibition are proper remedies to assail the constitutionality of RA 9522.
• 3. Whether RA 9522 is unconstitutional.

Ruling

• 1. The Supreme Court held that the petitioners possess locus standi as citizens with constitutionally sufficient interest in the resolution of the case.
• 2. The Court ruled that the writs of certiorari and prohibition are proper remedies to test the constitutionality of RA 9522.
• 3. The Court found no basis to declare RA 9522 unconstitutional: a. RA 9522 is a statutory tool to delineate the country's maritime zones and continental shelf under UNCLOS III, not to define Philippine territory. b. The law's use of the regime of islands to determine the maritime zones of the KIG and Scarborough Shoal is consistent with the Philippines' claim of sovereignty over these areas. c. The law does not result in the loss of Philippine territory. d. RA 9522 is not incompatible with the Constitution's delineation of internal waters.

Doctrines

• 1. Locus standi: The Court recognized the petitioners' standing as citizens with sufficient interest in issues of national significance.
• 2. Judicial review: The Court affirmed its power to review the constitutionality of statutes through the writs of certiorari and prohibition.
• 3. Constitutional interpretation: The Court interpreted the constitutional provision on national territory in light of international law and treaty obligations.
• 4. Pacta sunt servanda: The Court emphasized the Philippines' duty to comply with its treaty obligations under UNCLOS III in good faith.
• 5. Archipelagic doctrine: The Court recognized the Philippines' status as an archipelagic state under UNCLOS III and its implications for maritime boundaries.

Key Excerpts

• 1. "UNCLOS III has nothing to do with the acquisition (or loss) of territory. It is a multilateral treaty regulating, among others, sea-use rights over maritime zones."
• 2. "Baselines laws are nothing but statutory mechanisms for UNCLOS III States parties to delimit with precision the extent of their maritime zones and continental shelves."
• 3. "RA 9522 is therefore a most vital step on the part of the Philippines in safeguarding its maritime zones, consistent with the Constitution and our national interest."

Precedents Cited

• 1. Tanada v. Angara (338 Phil. 546, 580-581 [1997]): Cited to explain that the provisions in Article II of the Constitution are generally not self-executing and require implementing legislation.
• 2. Bayan Muna v. Romulo (G.R. No. 159618, February 1, 2011): Used to support the argument that treaties and international agreements have a limiting effect on sovereignty, and that states may voluntarily waive some aspects of their sovereignty for greater benefits.

Statutory and Constitutional Provisions

• 1. Article I (National Territory)
• 2. Article II, Section 7 (Nuclear-free policy)
• 3. Article II, Section 8 (Freedom from nuclear weapons)
• 4. Article II, Section 16 (Protection of marine wealth)
• 5. Article XII, Section 2 (National patrimony)
• 6. Article XIII, Section 7 (Protection of subsistence fishermen)