Class Suit -large number of people with a common interest in a matter to sue or be sued as a group

Locus Standing - the right to bring action in court.

The non-impairment clause is contained in Section 10, Article III of the Constitution, which provides that
no law impairing the obligation of contracts shall be passed. The non-impairment clause is limited in
application to laws that derogate from prior acts or contracts by enlarging, abridging or in any manner
changing the intention of the parties.
police poweris the power vested in the legislature by the Constitution to make, ordain, establish all manner of
wholesome and reasonable laws for the good and welfare of the State and its people.
The basic purposes of police power are:
a.

to promote the general welfare, comfort and convenience of the people;

b.

to promote and preserve public health;

The first complaint was filed as a taxpayer's class suit at the Branch 66 (Makati, Metro Manila), of the Regional Trial
Court, National capital Judicial Region against defendant (respondent) Secretary of the Department of Environment
and Natural Reasources (DENR).
Plaintiffs alleged that they are entitled to the full benefit, use and enjoyment of the natural resource treasure that is
the country's virgin tropical forests. They further asseverate that they represent their generation as well as
generations yet unborn and asserted that continued deforestation have caused a distortion and disturbance of the
ecological balance and have resulted in a host of environmental tragedies.
Plaintiffs prayed that judgement be rendered ordering the respondent, his agents, representatives and other persons
acting in his behalf to cancel all existing Timber License Agreement (TLA) in the country and to cease and desist from
receiving, accepting, processing, renewing or approving new TLAs.
Defendant, on the other hand, filed a motion to dismiss on the ground that the complaint had no cause of action
against him and that it raises a political question.
The RTC Judge sustained the motion to dismiss, further ruling that granting of the relief prayed for would result in the
impairment of contracts which is prohibited by the Constitution.
Plaintiffs (petitioners) thus filed the instant special civil action for certiorari and asked the court to rescind and set
aside the dismissal order on the ground that the respondent RTC Judge gravely abused his discretion in dismissing
the action.
First Issue: Cause of Action.
Respondents aver that the petitioners failed to allege in their complaint a specific legal right violated by the respondent Secretary for
which any relief is provided by law. The Court did not agree with this. The complaint focuses on one fundamental legal right -- the
right to a balanced and healthful ecology which is incorporated in Section 16 Article II of the Constitution. The said right carries with
it the duty to refrain from impairing the environment and implies, among many other things, the judicious management and
conservation of the country's forests. Section 4 of E.O. 192 expressly mandates the DENR to be the primary government agency
responsible for the governing and supervising the exploration, utilization, development and conservation of the country's natural
resources. The policy declaration of E.O. 192 is also substantially re-stated in Title XIV Book IV of the Administrative Code of 1987.
Both E.O. 192 and Administrative Code of 1987 have set the objectives which will serve as the bases for policy formation, and have
defined the powers and functions of the DENR. Thus, right of the petitioners (and all those they represent) to a balanced and
healthful ecology is as clear as DENR's duty to protect and advance the said right.
A denial or violation of that right by the other who has the correlative duty or obligation to respect or protect or respect the same
gives rise to a cause of action. Petitioners maintain that the granting of the TLA, which they claim was done with grave abuse of
discretion, violated their right to a balance and healthful ecology. Hence, the full protection thereof requires that no further TLAs
should be renewed or granted.
After careful examination of the petitioners' complaint, the Court finds it to be adequate enough to show, prima facie, the claimed
violation of their rights.

Second Issue: Political Issue.

Second paragraph, Section 1 of Article VIII of the constitution provides for the expanded jurisdiction vested upon the Supreme
Court. It allows the Court to rule upon even on the wisdom of the decision of the Executive and Legislature and to declare their acts
as invalid for lack or excess of jurisdiction because it is tainted with grave abuse of discretion.
Third Issue: Violation of the non-impairment clause.
The Court held that the Timber License Agreement is an instrument by which the state regulates the utilization and disposition of
forest resources to the end that public welfare is promoted. It is not a contract within the purview of the due process clause thus, the
non-impairment clause cannot be invoked. It can be validly withdraw whenever dictated by public interest or public welfare as in this
case. The granting of license does not create irrevocable rights, neither is it property or property rights.
Moreover, the constitutional guaranty of non-impairment of obligations of contract is limit by the exercise by the police power of the
State, in the interest of public health, safety, moral and general welfare. In short, the non-impairment clause must yield to the police
power of the State.
The instant petition, being impressed with merit, is hereby GRANTED and the RTC decision is SET ASIDE.