Cruz and Europa v. Secretary of Environment and Natural Resources

State machinery is set into motion to implement an alleged unconstitutional statute, this Court possesses sufficient authority to resolve and prevent imminent injury and violation of the constitutional process. B. Petitioners, as citizens and taxpayers, have the requisite standing to raise the constitutional questions herein. In addition to the existence of an actual case or controversy, a person who assails the validity of a statute must have a personal and substantial interest in the case, such that, he has sustained, or will sustain, a direct injury as a result of its enforcement.[35] Evidently, the rights asserted by petitioners as citizens and taxpayers are held in common by all the citizens, the violation of which may result only in a "generalized grievance".[36] Yet, in a sense, all citizen's and taxpayer's suits are efforts to air generalized grievances about the conduct of government and the allocation of power.[37] In several cases, the Court has adopted a liberal attitude with regard to standing.[38] The proper party requirement is considered as merely procedural,[39] and the Court has ample discretion with regard thereto.[40] As early as 1910, the Court in the case of Severino vs. Governor General [41] held: x x x [W]hen the relief is sought merely for the protection of private rights, the relator must show some personal or special interest in the subject matter, since he is regarded as the real party in interest and his right must clearly appear. Upon the other hand, when the question is one of public right and the object of the mandamus is to procure the enforcement of a public duty, the people are regarded as the real party in interest, and the relator at whose instigation the proceedings are instituted need not show that he has any legal or special interest in the result, it being sufficient to show that he is a citizen and as such interested in the execution of the laws.[42] This Court has recognized that a "public right," or that which belongs to the people at large, may also be the subject of an actual case or controversy. In Severino, we ruled that a private citizen may enforce a "public right" in behalf of other citizens. We opined therein that: ... [T]he right which [petitioner] seeks to enforce is not greater or different from that of any other qualified elector in the municipality of Silay. It is also true that the injury which he would suffer in case he fails to obtain the relief sought would not be greater or different from that of the other electors; but he is seeking to enforce a public right as distinguished from a private right. The real party in interest is the public, or the qualified electors of the town of Silay. Each elector has the same right and would suffer the same injury. Each elector stands on the same basis with reference to maintaining a petition whether or not the relief sought by the relator should be granted.[43] In Tañada v. Tuvera,[44] the Court enforced the "public right" to due process and to be informed of matters of public concern. In Garcia vs. Board of Investments,[45] the Court upheld the "public right" to be heard or consulted on matters of national concern. In Oposa v. Factoran,[46] the Court recognized the "public right" of citizens to "a balanced and healthful ecology which, for the first time in our nation's constitutional history, is solemnly incorporated in the fundamental law."