The Supreme Court upholds the constitutionality

of Republic Act No. 9522, adjusting the

archipelagic baselines of the Philippines in
accordance with UNCLOS III, dismissing the
petitioners' claims of territorial loss and violation
of constitutional provisions.

• The case "Magallona v. Ermita" involves petitioners

including Prof. Merlin M. Magallona, Akbayan Party-
List Rep. Risa Hontiveros, Prof. Harry C. Roque, Jr.,
and several University of the Philippines College of
Law students.

• They challenged the constitutionality of Republic Act

No. 9522 (RA 9522).

• Respondents include Hon. Eduardo Ermita, Executive

Secretary, Hon. Alberto Romulo, Secretary of the
 Department of Foreign A�airs, Hon. Rolando Andaya,
Secretary of the Department of Budget and
Management, Hon. Diony Ventura, Administrator of
the National Mapping & Resource Information
Authority, and Hon. Hilario Davide, Jr., Representative
of the Permanent Mission of the Republic of the
Philippines to the United Nations.

• Petitioners argued that RA 9522, which adjusted the

archipelagic baselines of the Philippines in
accordance with the United Nations Convention on
the Law of the Sea (UNCLOS III), resulted in the loss
of Philippine maritime territory and violated
constitutional provisions.

• The case was decided by the Supreme Court on

August 16, 2011, with Justice Carpio as the ponente.

1. Do the petitioners possess locus standi to bring this

suit?

2. Are the writs of certiorari and prohibition proper

remedies to assail the constitutionality of RA 9522?

3. Is RA 9522 unconstitutional?

1. The petitioners possess locus standi to bring this suit

as citizens.

2. The writs of certiorari and prohibition are proper

remedies to test the constitutionality of RA 9522.
3. RA 9522 is not unconstitutional.

• The Supreme Court held that the petitioners have

locus standi as citizens with a constitutionally
su�cient interest in the resolution of the case, which
raises issues of national signi�cance.

• The Court found that the writs of certiorari and

prohibition are appropriate remedies to challenge the
constitutionality of statutes.

• On the merits, the Court ruled that RA 9522 is a

statutory tool to demarcate the country's maritime
zones and continental shelf under UNCLOS III, not to
delineate Philippine territory.

• The Court emphasized that UNCLOS III regulates sea-

use rights over maritime zones and does not a�ect the
acquisition or loss of territory.

• Baselines laws, such as RA 9522, are mechanisms for

States to delimit their maritime zones and continental
shelves in compliance with UNCLOS III.

• The Court noted that RA 9522's classi�cation of the

Kalayaan Island Group (KIG) and the Scarborough
Shoal as "regimes of islands" is consistent with the
Philippines' claim of sovereignty over these areas and
does not result in territorial loss.

• Additionally, the Court found that RA 9522 does not

undermine the country's security, environment, or
economic interests, nor does it relinquish the
 Philippines' claim over Sabah.

• The Court concluded that RA 9522 is consistent with

the 1987 Constitution and the Philippines' obligations
under international law.
 A group of minors and an environmental
organization �le a complaint against the Secretary
of the Department of Environment and Natural
Resources, alleging violation of their right to a
balanced and healthful ecology through the
granting of timber license agreements; the
Supreme Court rules in favor of the plainti�s,
recognizing the right to a balanced and healthful
ecology as a fundamental legal right and a�rming
the justiciability of environmental issues.

• In "Oposa v. Factoran Jr.," a group of minors,

represented by their parents and the Philippine
Ecological Network, Inc. (PENI), �led a complaint
against the Secretary of the Department of
Environment and Natural Resources (DENR),
Fulgencio S. Factoran, Jr.
• The case, Civil Case No. 90-777, was �led before
Branch 66 of the Regional Trial Court (RTC) in Makati,
Metro Manila.

• The plainti�s argued that the continued granting of

timber license agreements (TLAs) by the DENR was
leading to the misappropriation and impairment of
the Philippines' rainforests, causing severe
environmental damage.

• They requested the cancellation of all existing TLAs

and a halt to the issuance of new ones.

• The RTC dismissed the case, ruling that the plainti�s

had no cause of action and that the issue was a
political question.

• The plainti�s then �led a special civil action for

certiorari with the Supreme Court, challenging the
RTC's dismissal.

1. Do the plainti�s have a cause of action to prevent the

misappropriation or impairment of Philippine
rainforests?

2. Is the issue raised by the plainti�s a political question

that should be addressed by the legislative or
executive branches of government?

3. Does the granting of the reliefs prayed for by the

plainti�s result in the impairment of contracts, which
is prohibited by the Constitution?
1. The Supreme Court ruled that the plainti�s do have a
cause of action to prevent the misappropriation or
impairment of Philippine rainforests.

2. The Court held that the issue raised by the plainti�s is

not a political question and is within the jurisdiction
of the judiciary.

3. The Court found that the granting of the reliefs prayed

for by the plainti�s does not result in the impairment
of contracts.

• The Supreme Court recognized the right to a balanced

and healthful ecology as a fundamental legal right,
explicitly provided for in Section 16, Article II of the
1987 Philippine Constitution.

• This right is linked to the right to health and is

essential for self-preservation and self-perpetuation.

• The Court emphasized that this right carries with it

the duty to refrain from impairing the environment.

• The Court noted that the DENR has a mandate to

protect and advance this right, as outlined in
Executive Order No. 192 and the Administrative Code
of 1987.

• The Court rejected the argument that the issue was a

political question, stating that the judiciary has the
duty to settle actual controversies involving legally
demandable and enforceable rights.
• The Court clari�ed that timber licenses are not
contracts protected by the non-impairment clause of
the Constitution, as they are merely privileges that
can be revoked in the interest of public welfare.

• The Court concluded that the plainti�s' complaint

su�ciently alleged a cause of action and that the case
should proceed to trial, with the timber license
holders being impleaded as indispensable parties.
 A group of petitioners, including religious leaders,
environmental activists, and political �gures, �le a
petition seeking environmental protection and
compensation for damages caused by the
grounding of a US warship on a protected marine
park, but the court dismisses the petition, citing
lack of legal standing and the doctrine of sovereign
immunity.

• : Religious leaders, environmental

activists, and political �gures.

• : US military o�cers and Philippine

government o�cials.

• : Grounding of the USS Guardian on the

Tubbataha Reefs on January 17, 2013.

• : Signi�cant environmental damage to the

 protected marine park.

• : Filed for a Writ of Kalikasan with a prayer

for a Temporary Environmental Protection Order
(TEPO).

• : Violation of constitutional rights to a

balanced and healthful ecology.

• : Compensation for damages, cessation

of military exercises, and a review of the Visiting
Forces Agreement (VFA).

• : Had not yet ruled on the matter.

• : Rendered on September 16,

2014, with Justice Villarama, Jr. as the ponente.

1. : Do the petitioners have legal standing

to �le the petition for a Writ of Kalikasan?

2. : Does the doctrine of sovereign

immunity apply to the US respondents, thereby
barring the court from exercising jurisdiction over
them?

3. : Are the reliefs sought by the

petitioners, including compensation for
environmental damage and cessation of military
exercises, warranted?

1. : The court ruled that the petitioners

 have legal standing to �le the petition for a Writ of
Kalikasan.

2. : The court held that the doctrine

of sovereign immunity applies to the US respondents,
thereby barring the court from exercising jurisdiction
over them.

3. : The court denied the petition for the

issuance of the privilege of the Writ of Kalikasan and
did not grant the reliefs sought by the petitioners.

• : Recognized based on the

liberalization of standing in environmental cases, as
established in Oposa v. Factoran, Jr.

• : The right to a balanced and

healthful ecology is of transcendental importance,
carrying the duty to refrain from impairing the
environment.

• : Enshrined in Article XVI,

Section 3 of the 1987 Philippine Constitution and
recognized under international law, bars the exercise
of jurisdiction over the US respondents.

• : A state cannot be sued without its

consent; the US had not waived its immunity in this
case.

• : Provides for the

treatment of US military personnel in the Philippines
but does not waive sovereign immunity for civil
 actions such as the petition for a Writ of Kalikasan.

• : Claims for compensation and

other reliefs should be addressed through diplomatic
channels, not judicial intervention.

• : Salvage operations had already been

completed, rendering some of the reliefs sought moot.
 An alien's application for registration and
acquisition of a residential lot in the Philippines is
denied, as the Constitution and laws disqualify
aliens from acquiring or holding lands of the
public domain.

• The case "Oh Cho v. Director of Lands" (G.R. No.

48321) was decided on August 31, 1946, by the
Philippine Supreme Court.

• Oh Cho, a Chinese citizen, sought the registration of a

residential lot in Guinayangan, Tayabas.

• The Director of Lands opposed the application,

arguing that as an alien, Oh Cho was disquali�ed from
acquiring lands of the public domain and lacked title
to the lot.

• The lot had been in open, continuous, exclusive, and

 notorious possession of Oh Cho and his predecessors
since 1880.

• The application for registration was �led on January

17, 1940.

• The Solicitor General contended that the lower court

erred in not declaring the sale of the lot to Oh Cho
null and void.

• Oh Cho invoked the Land Registration Act (Act No.

496) and alternatively, the Public Land Act (C.A. No.
141).

• The lower court ruled in favor of Oh Cho, decreeing

the registration of the lot in his name, leading to an
appeal by the Director of Lands.

1. Is the applicant, an alien, entitled to the registration of

the residential lot under the Land Registration Act or
the Public Land Act?

2. Should the sale of the lot to the applicant be declared

null and void?

1. The Supreme Court ruled that the applicant, being an

alien, is disquali�ed from acquiring lands of the
public domain and, therefore, is not entitled to a
decree of registration under the provisions of the
Public Land Act.

2. The Court did not �nd it necessary to declare the sale

 of the lot to the applicant null and void in this case, as
the vendors did not object to the application �led by
the vendee.

• The Court emphasized that all lands not acquired

from the Government by purchase or grant belong to
the public domain.

• An exception exists for land possessed by an

occupant and their predecessors since time
immemorial, suggesting the land was private
property before the Spanish conquest. This does not
apply here as the earliest possession was in 1880.

• Under the Public Land Act, an alien is disquali�ed

from acquiring lands of the public domain.

• The bene�ts under the Public Land Act for the

applicant's predecessors required applying for land
registration by July 26, 1894, which they failed to do.

• The applicant's predecessors had no vested right in

the lot to transmit to the applicant.

• The sale of the lot did not need to be declared null and
void since the vendors did not object to the
application.

• The lower court's judgment was reversed, and the

application for registration was dismissed.
 The Supreme Court declares Service Contract No.
46 null and void for violating the Philippine
Constitution and environmental laws, emphasizing
the importance of protecting the environment and
adhering to procedural requirements in the
exploration and utilization of natural resources.

• The case "Resident Marine Mammals of the Protected

Seascape Tańon Strait v. Reyes" involves two
consolidated petitions (G.R. Nos. 180771 and 181527)
�led under Rule 65 of the 1997 Rules of Court.

• These petitions challenge the legality of Service

Contract No. 46 (SC-46), which allowed the
exploration, development, and exploitation of
petroleum resources within the Tańon Strait, a
 protected seascape between Negros and Cebu.

• Petitioners in G.R. No. 180771 are the "Resident Marine

Mammals" represented by Gloria Estenzo Ramos and
Rose-Liza Eisma-Osorio as their legal guardians. They
seek to nullify SC-46 for violating the 1987
Constitution and various environmental laws.

• Petitioners in G.R. No. 181527 are the Central Visayas

Fisherfolk Development Center (FIDEC) and
individual �sherfolk, who also seek to nullify the
Environmental Compliance Certi�cate (ECC) issued
for SC-46 and to compel public respondents to
provide access to pertinent documents.

• Respondents include government o�cials such as the

late Secretary Angelo Reyes of the Department of
Energy (DOE), Secretary Jose L. Atienza of the
Department of Environment and Natural Resources
(DENR), and others, as well as Japan Petroleum
Exploration Co., Ltd. (JAPEX) and its alleged
Philippine agent, Supply Oil�eld Services, Inc. (SOS).

• The Government of the Philippines, through the DOE,

entered into a Geophysical Survey and Exploration
Contract-102 (GSEC-102) with JAPEX on June 13,
2002, which was later converted into SC-46 on
December 21, 2004.

• JAPEX conducted seismic surveys and drilling

activities in the Tańon Strait, declared a protected
seascape in 1998.

• Petitioners allege these activities caused signi�cant

 ecological damage and violated procedural
requirements for environmental protection.

• The lower courts did not resolve the issues, leading to

the �ling of these petitions before the Supreme Court.

1. Do the petitioners have legal standing (locus standi)

to �le the petitions?

2. Is Service Contract No. 46 (SC-46) violative of the 1987

Philippine Constitution and other relevant laws?

3. Does the issuance of the Environmental Compliance

Certi�cate (ECC) for SC-46 conform to legal and
procedural requirements?

4. Can the respondents be compelled by mandamus to

furnish petitioners with copies of documents
pertaining to the Tańon Strait Oil Exploration Project?

1. The Supreme Court ruled that the Stewards (Ramos

and Eisma-Osorio) have legal standing to �le the
petition on behalf of the Resident Marine Mammals.

2. Service Contract No. 46 (SC-46) is declared null and

void for violating the 1987 Constitution, Republic Act
No. 7586 (NIPAS Act), and Presidential Decree No.
1586.

3. The issuance of the Environmental Compliance

Certi�cate (ECC) for SC-46 did not conform to legal
and procedural requirements.
4. The respondents may be compelled by mandamus to
furnish petitioners with copies of documents
pertaining to the Tańon Strait Oil Exploration Project.

1. :

• The Court recognized the Stewards' legal

standing based on the liberalized approach to
environmental cases, allowing any Filipino
citizen to �le an action to enforce environmental
laws.

• The Court emphasized that the Stewards have

shown possible violations of laws concerning the
habitat of the Resident Marine Mammals, thus
granting them the right to �le the petition.

2. :

• The Court found SC-46 null and void for non-

compliance with the 1987 Constitution, which
requires that the President himself enter into any
service contract for the exploration of petroleum.

• SC-46 was signed only by the DOE Secretary, and

there was no evidence that Congress was noti�ed
of the contract.

• Additionally, the Court held that Presidential

Decree No. 87, which governs oil exploration,
remains valid but must be harmonized with the
 1987 Constitution and other environmental laws.

3. :

• The Court ruled that the ECC issued for SC-46

was invalid as it did not comply with the
procedural and substantive requirements under
the Environmental Impact Assessment (EIA)
system.

• The seismic surveys conducted by JAPEX were

done without an ECC, violating the NIPAS Act and
Presidential Decree No. 1586.

4. :

• The Court held that the respondents could be

compelled by mandamus to provide petitioners
with copies of documents related to the Tańon
Strait Oil Exploration Project, as transparency
and access to information are essential for
environmental protection and public
participation.
 The Supreme Court a�rms its authority to issue
directives and set deadlines for government
agencies to clean up and rehabilitate Manila Bay,
despite dissenting opinions arguing it encroaches
on the executive branch's authority.

• The case involves a petition by several government

agencies, including the Metropolitan Manila
Development Authority (MMDA) and the Department
of Environment and Natural Resources (DENR),
against the Concerned Residents of Manila Bay.

• The Supreme Court of the Philippines rendered a

decision on February 15, 2011, a�rming its authority
to issue directives and set deadlines for these
government agencies to clean up and rehabilitate
 Manila Bay.

• The case originated from a decision by the Regional

Trial Court (RTC) on September 13, 2002, which was
a�rmed by the Court of Appeals (CA) on September
28, 2005.

• The RTC had ordered the defendant-government

agencies to clean up, rehabilitate, and preserve
Manila Bay to make its waters �t for swimming and
other forms of contact recreation.

• The Supreme Court's decision became �nal in

January 2009, and the case entered the execution
phase.

• The Manila Bay Advisory Committee was created to

monitor the execution of the �nal decision and
evaluate the quarterly progressive reports submitted
by the agencies.

• Does the Supreme Court have the authority to issue

directives and set deadlines for government agencies
to clean up and rehabilitate Manila Bay?

• Do these directives encroach upon the executive

branch's authority?

• Yes, the Supreme Court has the authority to issue

directives and set deadlines for government agencies
to clean up and rehabilitate Manila Bay.
• No, these directives do not encroach upon the
executive branch's authority.

• The Supreme Court's authority to issue directives and

set deadlines for the cleanup and rehabilitation of
Manila Bay is rooted in its judicial power under
Article VIII of the 1987 Philippine Constitution.

• The Court emphasized that the execution of its

decision is an integral part of its adjudicative
function.

• The issuance of subsequent resolutions is a

continuation of the Court's judicial power to ensure
that its �nal judgment is fully implemented.

• The Court noted that none of the agencies questioned

its power to implement the December 18, 2008
decision, nor did they raise concerns about alleged
encroachment on executive functions.

• The submission of periodic reports by the agencies is

sanctioned by Sections 7 and 8, Rule 8 of the Rules of
Procedure for Environmental Cases.

• These rules allow the Court to require respondents to

submit periodic reports detailing the progress and
execution of the judgment.

• The concept of "continuing mandamus" means that

the Court exercises continuing jurisdiction over the
agencies until full compliance with the judgment is
achieved.
• The Court addressed concerns about potential
encroachment on executive functions by clarifying
that its directives are necessary to implement the
�nal judgment.

• The Court's role is to ensure that the agencies

perform their duties as mandated by law, and the
submission of plans of action and status reports is
part of the execution stage of the �nal decision.

• The principle of separation of powers does not

preclude the judiciary from ensuring that its
decisions are e�ectively implemented.

• In conclusion, the Supreme Court a�rmed its

authority to issue directives and set deadlines for the
cleanup and rehabilitation of Manila Bay,
emphasizing that these actions are within its judicial
power and do not encroach upon the executive
branch's authority.
 The Supreme Court of the Philippines ruled that
private claimants in Boracay Island are not entitled
to secure titles over their occupied lands,
upholding the validity of Proclamation No. 1064
which classi�ed Boracay into reserved forest and
agricultural land, but suggested alternative options
for private claimants to acquire title to their
occupied lots.

• The case involves two consolidated petitions

regarding the right of current occupants of Boracay
Island to secure titles over their occupied lands.

• A petition for review

on certiorari of the Court of Appeals (CA) decision
a�rming the Regional Trial Court (RTC) in Kalibo,
Aklan, which granted a petition for declaratory relief
 �led by respondents-claimants Mayor Jose Yap,
Libertad Talapian, Mila Y. Sumndad, and Aniceto Yap.
The RTC ordered the survey of Boracay for titling
purposes.

• A petition for
prohibition, mandamus, and nulli�cation of
Proclamation No. 1064 issued by President Gloria
Macapagal-Arroyo, which classi�ed Boracay into
reserved forest and agricultural land.

• Boracay Island is a premier tourist destination with

12,003 inhabitants.

• On April 14, 1976, the Department of Environment and

Natural Resources (DENR) approved the National
Reservation Survey of Boracay Island.

• On November 10, 1978, President Ferdinand Marcos

issued Proclamation No. 1801, declaring Boracay
Island as a tourist zone and marine reserve under the
administration of the Philippine Tourism Authority
(PTA).

• Respondents-claimants �led a petition for declaratory

relief, alleging doubts about their right to secure titles
over their occupied lands due to Proclamation No.
1801 and PTA Circular No. 3-82.

• The RTC ruled in favor of the respondents-claimants,

stating that Proclamation No. 1801 and PTA Circular
No. 3-82 posed no legal obstacle to acquiring titles.
The CA a�rmed this decision.

• During the pendency of G.R. No. 167707, President

 Gloria Macapagal-Arroyo issued Proclamation No.
1064 on May 22, 2006, classifying Boracay into
reserved forest land and agricultural land.

• Petitioners-claimants Dr. Orlando Sacay and Wilfredo

Gelito, along with other landowners, �led a petition
for prohibition, mandamus, and nulli�cation of
Proclamation No. 1064, claiming it infringed on their
vested rights.

1. Does Proclamation No. 1801 and PTA Circular No. 3-82

pose any legal obstacle for respondents to acquire
title to their occupied lands in Boracay Island?

2. At the time of the established possession of

petitioners in concept of owner over their respective
areas in Boracay, were the areas occupied by them
public agricultural lands or public forest as de�ned by
Sec. 3a, PD 705?

3. Have petitioners occupants acquired prior vested

rights of private ownership over their occupied
portions of Boracay land, despite not applying for
judicial con�rmation of imperfect title?

4. Is the executive declaration of their areas as alienable

and disposable under Sec 6, CA 141 an indispensable
prerequisite for petitioners to obtain title under the
Torrens system?

5. Is the issuance of Proclamation 1064 on May 22,

2006, violative of the prior vested rights to private
 ownership of petitioners over their lands in Boracay,
protected by the due process clause of the
Constitution or contrary to Sec. 8, CA 141, or Sec. 4(a)
of RA 6657?

6. Can respondents be compelled by mandamus to allow

the survey and to approve the survey plans for
purposes of the application for titling of the lands of
petitioners in Boracay?

1. The petition for certiorari in G.R. No. 167707 is

granted, and the Court of Appeals Decision in CA-G.R.
CV No. 71118 is reversed and set aside.

2. The petition for certiorari in G.R. No. 173775 is

dismissed for lack of merit.

• The Supreme Court ruled that private claimants in

Boracay Island are not entitled to secure titles over
their occupied lands.

• The Court upheld the validity of Proclamation No.

1064, which classi�ed Boracay into reserved forest
and agricultural land.

• The Court emphasized the Regalian Doctrine, which

dictates that all lands of the public domain belong to
the State, and only agricultural lands may be
alienated.

• Boracay Island, prior to Proclamation No. 1064, was

 an unclassi�ed land of the public domain and
considered public forest under PD No. 705.

• The classi�cation of Boracay as a forest land under

PD No. 705 did not bar the Executive from later
converting it into agricultural land.

• Proclamation No. 1801 did not convert Boracay into

agricultural land; the island remained unclassi�ed
until Proclamation No. 1064.

• Private claimants failed to prove the requisite period

of possession and occupation since June 12, 1945, and
their tax declarations were insu�cient to establish
such possession.

• Private claimants' continued possession and

investments do not automatically give them a vested
right to apply for a title.

• The Court suggested that private claimants could

explore other modes of applying for original
registration of title, such as by homestead or sales
patent, or seek legislative intervention for their plight.