G.R. No. 180771 & 181527, April 21, 2015
Resident Marine Mammals of the Protected Seascape Tañon Strait, et al. v. Angelo Reyes, et al. / Central Visayas Fisherfolk Development Center (FIDEC), et al. v. Angelo Reyes, et al.

FACTS

Two consolidated petitions were filed challenging the oil exploration activities by Japan Petroleum Exploration Co., Ltd. (JAPEX) in the Tañon Strait Protected Seascape. In G.R. No. 180771 , the petitioners were the “Resident Marine Mammals of the Protected Seascape Tañon Strait” (e.g., toothed whales, dolphins, porpoises), joined and represented by human beings Gloria Estenzo Ramos and Rose-Liza Eisma-Osorio, who claimed capacity as “legal guardians of the lesser life-forms and as responsible stewards of God’s Creations.” They based their claim on the right to enforce environmental laws for the benefit of the marine mammals under the concept of stipulation pour autrui and the doctrine of public trust, citing Oposa v. Factoran, Jr. They also asked the court to lower the threshold for locus standi through “epistolary jurisdiction.” In G.R. No. 181527, the petitioners were fisherfolk organizations and individuals representing subsistence fisherfolk and future generations affected by the oil exploration.

ISSUE

The primary procedural issue relevant to the provided text is whether the Resident Marine Mammals, as non-human entities, have legal standing to sue and whether the human petitioners can properly represent them in a judicial capacity.

RULING

The Supreme Court, through the Concurring Opinion of Justice Leonen, held that animals, such as the Resident Marine Mammals, do not have legal standing to sue. The 1997 Rules of Civil Procedure, Rule 3, Section 1, provides that only natural or juridical persons, or entities authorized by law, may be parties in a civil action. The Civil Code defines natural persons (Article 40) and juridical persons (Article 44), which do not include animals. The Resident Marine Mammals are not natural or juridical persons and are not authorized by law to be parties. Furthermore, for representation under Rule 3, Section 3, the representative must be authorized by law or the Rules, which the human petitioners are not. The Court cannot amend the Rules or substantive law to grant animals legal personality. The human petitioners themselves, however, already possess legal standing to sue on the environmental issues raised based on the liberalized rules for asserting environmental rights. The zeal of the advocates is commendable, but fundamental judicial doctrines cannot be founded on feigned representation. The proper parties are the human petitioners asserting their own interests and the public interest in a balanced and healthful ecology.