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ANGARA international law, which are considered automatically part of

our own laws. Pacta sunt servanda international
Facts : agreements must be performed in good faith. A treaty is not
This is a petition seeking to nullify the Philippine ratification a mere moral obligation but creates a legally binding
of the World Trade Organization (WTO) Agreement. Petitioner- obligation on the parties.
senators Wigberto Tanada and Ana Dominique Coseteng
question the concurrence of respondents acting in their By their inherent nature, treaties really limit or restrict the
capacities as Senators via signing the said agreement. absoluteness of sovereignty. By their voluntary act, nations
may surrender some aspects of their state power in
The WTO Agreement opens access to foreign markets, exchange for greater benefits granted by or derived from a
especially its major trading partners, through the reduction of convention or pact. After all, states, like individuals, live with
tariffs on its exports, particularly agricultural and industrial coequals, and in pursuit of mutually covenanted objectives
products, paving the way for the implementation of and benefits, they also commonly agree to limit the exercise
neoliberal econmic policies under the Ramos administration. of their otherwise absolute rights. Thus, treaties have been
Petitioners, on the other hand, viewed the WTO agreement as used to record agreements between States concerning such
one that limits the Philippine economic sovereignty and widely diverse matters as, for example, the lease of naval
restricts the development of local industries. bases, the sale or cession of territory, the termination of war,
the regulation of conduct of hostilities, the formation of
Issue : Whether or not there has been a grave abuse of alliances, the regulation of commercial relations, the settling
discretion amounting to lack or excess of jurisdiction on the of claims, the laying down of rules governing conduct in
part of the Senate in giving its concurrence of the said WTO peace and the establishment of international organizations.
agreement. The sovereignty of a state therefore cannot in fact and in
Held: reality be considered absolute. Certain restrictions enter into
No. In its Declaration of Principles and State Policies, the the picture: (1) limitations imposed by the very nature of
Constitution adopts the generally accepted principles of membership in the family of nations and (2) limitations
international law as part of the law of the land, and adheres imposed by treaty stipulations.
to the policy of peace, equality, justice, freedom, cooperation Petition is DISMISSED for lack of merit.
and amity , with all nations. By the doctrine of incorporation,
the country is bound by generally accepted principles of