GR 97787; (August, 1996) (Digest)
G.R. No. 97787 August 1, 1996
The Anti-Graft League of the Philippines, Inc., represented by Reynaldo L. Bagatsing, petitioner, vs. Hon. Reynaldo San Juan, Provincial Governor, et al., respondents.
FACTS
The Anti-Graft League of the Philippines, a non-governmental organization, filed a petition for certiorari as a taxpayer’s suit. It sought to nullify a compromise agreement approved by the Regional Trial Court (RTC) of Pasig on March 21, 1989. The agreement resolved a case for rescission of contract filed by Ortigas & Company Ltd. against the Province of Rizal. The dispute originated from the Province’s 1975 purchase of land from Ortigas for a college site, a project later abandoned. In 1987, the Provincial Board authorized the land’s sale to a third party. Ortigas sued, alleging a contractual violation. The new provincial officials later rescinded that sale.
The RTC-approved compromise agreement required the Province to reconvey the land to Ortigas at P2,250 per square meter, payable within two years. Ortigas completed payment on March 30, 1991. The petitioner filed its suit on April 1, 1991, arguing the reconveyance constituted an illegal disbursement of public funds, as the agreed price exceeded other appraisals.
ISSUE
1. Does the petitioner possess legal standing (locus standi) to file this taxpayer’s suit?
2. Was the petition filed in the proper forum and in a timely manner?
RULING
The Supreme Court dismissed the petition. On legal standing, the Court held the petitioner lacked locus standi. A taxpayer’s suit requires that public funds are disbursed and that the petitioner is directly affected by the alleged illegal act. Here, the disbursement of funds occurred in 1975 for the original purchase, which the petitioner did not challenge. The 1989 compromise agreement involved a reconveyance to the Province (Ortigas paying the Province), not a disbursement from public coffers. The petitioner, not being a party to the contract, had no cause of action and thus no standing to question the private transaction between the Province and Ortigas.
Procedurally, the petition was fatally defective. The proper remedy to assail the RTC’s judgment approving the compromise was a petition for review with the Court of Appeals, not an original action for certiorari with the Supreme Court, as it involved a review of the trial court’s factual determinations. Furthermore, the action was barred by laches. The RTC decision became final in April 1989, yet the petitioner filed only in April 1991, without justification for the two-year delay. Having no standing and filing an improper, belated petition, the Court found no reason to rule on the merits.