The petitioners argued that the Visiting Forces Agreement (VFA) between the Philippines and United States violates the Philippine constitution. However, the Supreme Court ruled:
1) The petitioners did not have legal standing as taxpayers to challenge the agreement.
2) Section 25 of the constitution, regarding foreign military treaties, took precedence over the general treaty approval section.
3) The VFA satisfied Section 25's requirements to be treated as a valid treaty, including recognition by both states as such. Therefore, the petition was dismissed.
The petitioners argued that the Visiting Forces Agreement (VFA) between the Philippines and United States violates the Philippine constitution. However, the Supreme Court ruled:
1) The petitioners did not have legal standing as taxpayers to challenge the agreement.
2) Section 25 of the constitution, regarding foreign military treaties, took precedence over the general treaty approval section.
3) The VFA satisfied Section 25's requirements to be treated as a valid treaty, including recognition by both states as such. Therefore, the petition was dismissed.
The petitioners argued that the Visiting Forces Agreement (VFA) between the Philippines and United States violates the Philippine constitution. However, the Supreme Court ruled:
1) The petitioners did not have legal standing as taxpayers to challenge the agreement.
2) Section 25 of the constitution, regarding foreign military treaties, took precedence over the general treaty approval section.
3) The VFA satisfied Section 25's requirements to be treated as a valid treaty, including recognition by both states as such. Therefore, the petition was dismissed.
The petitioners argued that the Visiting Forces Agreement (VFA) between the Philippines and United States violates the Philippine constitution. However, the Supreme Court ruled:
1) The petitioners did not have legal standing as taxpayers to challenge the agreement.
2) Section 25 of the constitution, regarding foreign military treaties, took precedence over the general treaty approval section.
3) The VFA satisfied Section 25's requirements to be treated as a valid treaty, including recognition by both states as such. Therefore, the petition was dismissed.
Petitioner: Bayan (Bagong Alyansang Makabayan), a Junk VFA Movement, Bishop Tomas Millamena (Iglesia Filipina Independiente), Bishop Elmer Bolocan (United Church Of Christ Of The Phil.), Dr. Reynaldo Legasca, MD, Kilusang Mambubukid ng Pilipinas, Kilusang Mayo Uno, Gabriela, Prolabor, and, the Public Interest Law Center Respondent: Executive Secretary Ronaldo Zamora, Foreign Affairs Secretary Domingo Siazon, Defense Secretary Orlando Mercado, Brig. Gen. Alexander Aguirre, Senate President Marcelo Fernan, Senator Franklin Drilon, Senator Blas Ople, Senator Rodolfo Biazon, and Senator Francisco Tatad Ponente: J. Bueno Date: October 10, 2000
Facts: The Republic of the Philippines and the United States of America entered into an agreement called the Visiting Forces Agreement (VFA). The agreement was treated as a treaty by the Philippine government and was ratified by then-President Joseph Estrada with the concurrence of 2/3 of the total membership of the Philippine Senate.
The VFA defines the treatment of U.S. troops and personnel visiting the Philippines. It provides for the guidelines to govern such visits, and further defines the rights of the U.S. and the Philippine governments in the matter of criminal jurisdiction, movement of vessel and aircraft, importation and exportation of equipment, materials and supplies.
Petitioners argued, inter alia, that the VFA violates Section 25, Article XVIII of the 1987 Constitution, which provides that “foreign military bases, troops, or facilities shall not be allowed in the Philippines except under a treaty duly concurred in by the Senate . . . and recognized as a treaty by the other contracting State.”
Issues: 1. w/n the petitioners, as tax payers, have legal standing to sue 2. w/n it is Section 25, Article XVIII or Section 21, Article VII applies to the VFA 3. w/n Section 25, Article XVIII's requisites were satisfied to make the VFA effective
Held: 1. The petitioners do not possess locus standi. The petitioners failed to prove to the Court that they “have sustained, or are in danger of sustaining any direct injury as a result of the enforcement of the VFA”. As tax payers, they are not directly affected because there is no involvement of public funds in this case.
2. Section 25, Article XVIII should apply to the case. Statutory construction states that a special provision or law prevails over a general one, thus in this case, Section 25, Article XVIII, which specifically deals with treaties that involve foreign military bases, troops or facilities, wins over Section 21, Article VII, which deals with approval of treaties in general.
3. Section 25, Article XVIII's requisites were satisfied to make the VFA effective. All requisites have been properly fulfilled. The third requisite was proven to be fulfilled because of records of Ambassador Hubbard stating that the United States has fully committed to living up to the terms of the agreement.
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