Primary Holding

The Supreme Court established that the constitutional right to a balanced and healthful ecology is a fundamental, self-executing legal right. It upheld the principle of intergenerational responsibility, affirming the standing of minors to assert environmental claims on behalf of future generations.

Background

The case originated from Civil Case No. 90-777 filed in the Regional Trial Court (RTC) of Makati by a group of minors, represented by their parents, along with the Philippine Ecological Network, Inc. They sued then Secretary of the Department of Environment and Natural Resources (DENR), Fulgencio Factoran, Jr., for failing to cancel TLAs, which they claimed led to massive deforestation, causing environmental destruction. The RTC dismissed the case, ruling that it involved a political question and that the plaintiffs had no cause of action. The petitioners then elevated the case to the Supreme Court.

Facts

• 1. The Philippines’ rainforest cover had been drastically reduced from 16 million hectares to approximately 1.2 million hectares by 1987 due to deforestation.
• 2. The government had granted TLAs permitting extensive logging, which petitioners contended led to significant environmental degradation, including soil erosion, biodiversity loss, and climate change.
• 3. The petitioners invoked their constitutional right to a balanced and healthful ecology and sought the cancellation of TLAs.

Arguments of the Petitioners

• 1. The right to a balanced and healthful ecology, enshrined in Article II, Section 16 of the 1987 Constitution, is legally enforceable.
• 2. The government has an affirmative duty to protect environmental resources for both present and future generations.
• 3. The continued issuance of TLAs constitutes an unlawful deprivation of a fundamental right.

Arguments of the Respondents

• 1. Petitioners lacked standing as they had not suffered direct injury.
• 2. The case involved a political question beyond the judiciary’s competence.
• 3. TLAs were contracts protected by the non-impairment clause of the Constitution.

Issues

• 1. Do the petitioners have the requisite standing to sue in defense of environmental rights?
• 2. Is the constitutional right to a balanced and healthful ecology enforceable absent implementing legislation?
• 3. Does the continued issuance of TLAs constitute a violation of petitioners’ constitutional rights?

Ruling

• 1. Legal Standing: The Court ruled that the petitioners, including minors, had standing under the doctrine of intergenerational responsibility, allowing them to act on behalf of succeeding generations.
• 2. Self-Executing Right: The right to a balanced and healthful ecology does not require enabling legislation and is judicially enforceable.
• 3. Governmental Duty: The State’s obligation to protect the environment is derived from both constitutional and statutory mandates. The DENR’s failure to halt deforestation constituted grave abuse of discretion.
• 4. Rejection of the Political Question Doctrine: The judiciary has the authority to review executive actions affecting constitutional rights, rejecting respondents' contention that the matter was non-justiciable.
• 5. Licenses vs. Contracts: TLAs are privileges rather than contracts and can be revoked in the public interest without violating the non-impairment clause.

Doctrines

• 1. Intergenerational Responsibility: The duty to protect the environment extends beyond present interests to future generations.
• 2. Public Trust Doctrine: Natural resources are held in trust by the State for the benefit of all citizens, precluding their misallocation or over-exploitation.
• 3. Expanded Judicial Review (Art. VIII, Sec. 1 of the 1987 Constitution): Courts possess the authority to nullify executive actions that constitute grave abuse of discretion.

Key Excerpts

• 1. “Every generation has a responsibility to the next to preserve the rhythm and harmony of nature.”
• 2. “The right to a balanced and healthful ecology is fundamental, directly enforceable, and imposes an obligation upon the State to ensure its realization.”

Precedents Cited

• 1. Tan v. Director of Forestry (1983): Confirmed that timber licenses are revocable privileges, not contracts.
• 2. Ysmael v. Deputy Executive Secretary (1990): Reaffirmed the government's regulatory authority over timber resources.
• 3. Abe v. Foster Wheeler Corp. (1960): Established that private contractual rights are subordinate to public welfare concerns.
• 4. Nebia v. New York (1934, U.S. Supreme Court): Addressed the interplay between private rights and state regulatory authority.

Statutory and Constitutional Provisions

• 1. 1987 Constitution: (1) Art. II, Sec. 16: Right to a balanced and healthful ecology. (2) Art. XII, Sec. 2: State ownership and control of natural resources. (3) Art. III, Sec. 10: Non-impairment of contracts (held inapplicable to TLAs).
• 2. Presidential Decrees: (1) P.D. 1151: Philippine Environmental Policy. (2) P.D. 1152: Philippine Environment Code.
• 3. Executive Orders: (1) E.O. 192: DENR Reorganization Act. (2) Administrative Code of 1987, Title XIV, Book IV.