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1. Oposa vs. Factoran Case Digest (G.R. No.

101083, July 30, 1993)


FACTS:
A taxpayer’s class suit was filed by minors Juan Antonio Oposa, et al., representing their generation and generations yet unborn, and
represented by their parents against Fulgencio Factoran Jr., Secretary of DENR. They prayed that judgment be rendered ordering the
defendant, his agents, representatives and other persons acting in his behalf to:

1. Cancel all existing Timber Licensing Agreements (TLA) in the country;


2. Cease and desist from receiving, accepting, processing, renewing, or appraising new TLAs;

and granting the plaintiffs “such other reliefs just and equitable under the premises.” They alleged that they have a clear and
constitutional right to a balanced and healthful ecology and are entitled to protection by the State in its capacity as parens patriae.
Furthermore, they claim that the act of the defendant in allowing TLA holders to cut and deforest the remaining forests constitutes a
misappropriation and/or impairment of the natural resources property he holds in trust for the benefit of the plaintiff minors and
succeeding generations.
The defendant filed a motion to dismiss the complaint on the following grounds:

1. Plaintiffs have no cause of action against him;


2. The issues raised by the plaintiffs is a political question which properly pertains to the legislative or executive branches
of the government.

ISSUES:

(1) Whether or not the plaintiffs have a cause of action.


(2) Whether or not the complaint raises a political issue.
(3) Whether or not the original prayer of the plaintiffs result in the impairment of contracts.

RULING:

First Issue: Cause of Action.

Yes, petitioners have a cause of action. The case at bar is of common interest to all Filipinos. The right to a balanced and
healthy ecology carries with it the correlative duty to refrain from impairing the environment. The said right implies the
judicious management of the country’s forests. This right is also the mandate of the government through DENR. A denial
or violation of that right by the other who has the correlative duty or obligation to respect or protect the same gives rise
to a cause of action. All licenses may thus be revoked or rescinded by executive action.

Second Issue: Political Issue.

Second paragraph, Section 1 of Article VIII of the constitution provides for the expanded jurisdiction vested upon the
Supreme Court. It allows the Court to rule upon even on the wisdom of the decision of the Executive and Legislature and
to declare their acts as invalid for lack or excess of jurisdiction because it is tainted with grave abuse of discretion.

Third Issue: Violation of the non-impairment clause.

The Court held that the Timber License Agreement is an instrument by which the state regulates the utilization and
disposition of forest resources to the end that public welfare is promoted. It is not a contract within the purview of the
due process clause thus, the non-impairment clause cannot be invoked. It can be validly withdraw whenever dictated by
public interest or public welfare as in this case. The granting of license does not create irrevocable rights, neither is it
property or property rights.

Moreover, the constitutional guaranty of non-impairment of obligations of contract is limit by the exercise by the police
power of the State, in the interest of public health, safety, moral and general welfare. In short, the non-impairment
clause must yield to the police power of the State.

The instant petition, being impressed with merit, is hereby GRANTED and the RTC decision is SET ASIDE.