1. CAN THE TREES BE REPRESENTED IN THE CASE?

This question is interrelated to the issue on the legal standing or locus standi of the trees; thus,
the latter must be taken into consideration as well. There are differing views on this matter
though. However, Justice William Douglas in his dissenting opinion in the case of Sierra Club v.
Rogers Morton provided a substantial justification on the notion that animals or even non-living
objects have locus standi. Inanimate objects are sometimes parties in litigation. A ship has a
legal personality, a fiction found useful for maritime purposes. The corporation sole - a creature
of ecclesiastical law - is an acceptable adversary and large fortunes ride on its cases. The
ordinary corporation is a "person" for purposes of the adjudicatory processes, whether it
represents proprietary, spiritual, aesthetic, or charitable causes. So it should be as respects
valleys, alpine meadows, rivers, lakes, estuaries, beaches, ridges, groves of trees, swampland, or
even air that feels the destructive pressures of modern technology and modem life. The river, for
example, is the living symbol of all the life it sustains or nourishesfish, aquatic insects, water
ouzels, otter, fisher, deer, elk, bear, and all other animals, including man, who are dependent on it
or who enjoy it for its sight, its sound, or its life. The river as plaintiff speaks for the ecological
unit of life that is part of it. Those people who have a meaningful relation to that body of water
whether it be a fisherman, a canoeist, a zoologist, or a loggermust be able to speak for the
values which the river represents and which are threatened with destruction. Clearly, trees have
the locus standi as they represent the ecology that is being destroyed. Once these trees are cut, it
will infringe the right to a healthy environment of the inhabitants as a result of impairing the
ecological balance within the area.
The Court in its decision leans on the doctrine that "the rule on standing is a matter of procedure,
hence, can be relaxed for non-traditional plaintiffs like ordinary citizens, taxpayers, and
legislators when the public interest so requires, such as when the matter is of transcendental
importance, of overreaching significance to society, or of paramount public interest."
In Coconut Oil Refiners Association, Inc. v. Torres, the Court held that in cases of paramount
importance where serious constitutional questions are involved, the standing requirement may be
relaxed and a suit may be allowed to prosper even where there is no direct injury to the party
claiming the right of judicial review.
Thus, the trees can be represented because it is a matter of transcendental importance, of
overreaching significance to society, or of paramount public interest since the environment,
where all of its inhabitants including man, is at stake.
Undeniably, in the Philippine judicial system, issues on locus standi in environmental cases shall
be given a more liberalized approach. Accordingly, the Court passed the landmark Rules of
Procedure for Environmental Cases which allow for a citizen suit and permit any Filipino citizen
to file an action before our courts for violations of our environmental laws. In Oposa v. Facturan,
the Supreme Court allowed the suit to be brought in the name of generations yet unborn based
on the concept of intergenerational responsibility in so far as the right to a balanced and healthful

ecology is concerned. If that was the case, then Citizens for Nature shouldnt be prohibited to
represent the trees. Moreover, there shouldnt be any question on the right of the Citizens for
Nature to represent the trees as they are but exercising their stewardship of the environment.

Locus standi or legal standing is defined as a personal and substantial interest in a case such that
the party has sustained or will sustain direct injury as a result of the challenged governmental
act. It requires a personal stake in the outcome of the controversy as to assure the concrete
adverseness which sharpens the presentation of issues upon which the court so largely depends
for illumination of difficult constitutional questions.
Hence, the implementation of such project will cause an injury to the inhabitants of the affected
areas since the effects of cutting- off trees would pose a great danger.