The Supreme Court ruled that the Integrated Bar of the Philippines (IBP) did not have legal standing to challenge the President's deployment of the Philippine Marines to assist the Philippine National Police in anti-crime efforts. The Court held that the IBP failed to show how it had a personal and substantial interest in the case, and that its duty to uphold the constitution was too general of an interest. The Court also held that it could not exercise judicial review over the President's determination that deploying the Marines was necessary unless there was an actual case or controversy, which was lacking since the IBP did not demonstrate a direct injury.
The Supreme Court ruled that the Integrated Bar of the Philippines (IBP) did not have legal standing to challenge the President's deployment of the Philippine Marines to assist the Philippine National Police in anti-crime efforts. The Court held that the IBP failed to show how it had a personal and substantial interest in the case, and that its duty to uphold the constitution was too general of an interest. The Court also held that it could not exercise judicial review over the President's determination that deploying the Marines was necessary unless there was an actual case or controversy, which was lacking since the IBP did not demonstrate a direct injury.
The Supreme Court ruled that the Integrated Bar of the Philippines (IBP) did not have legal standing to challenge the President's deployment of the Philippine Marines to assist the Philippine National Police in anti-crime efforts. The Court held that the IBP failed to show how it had a personal and substantial interest in the case, and that its duty to uphold the constitution was too general of an interest. The Court also held that it could not exercise judicial review over the President's determination that deploying the Marines was necessary unless there was an actual case or controversy, which was lacking since the IBP did not demonstrate a direct injury.
The Supreme Court ruled that the Integrated Bar of the Philippines (IBP) did not have legal standing to challenge the President's deployment of the Philippine Marines to assist the Philippine National Police in anti-crime efforts. The Court held that the IBP failed to show how it had a personal and substantial interest in the case, and that its duty to uphold the constitution was too general of an interest. The Court also held that it could not exercise judicial review over the President's determination that deploying the Marines was necessary unless there was an actual case or controversy, which was lacking since the IBP did not demonstrate a direct injury.
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IBP vs.
Zamora G.R. No.141284 August 15, 2000
Facts: Invoking his powers as Commander-in-Chief under Sec. 18, Art. VII of the Constitution, the President directed the AFP Chief of Staff and PNP Chief to coordinate with each other for the proper deployment and utilization of the Marines to assist the PNP in preventing or suppressing criminal or lawless violence. The President declared that the services of the Marines in the anti-crime campaign are merely temporary in nature and for a reasonable period only, until such time when the situation shall have improved. The IBP filed a petition seeking to declare the deployment of the Philippine Marines null and void and unconstitutional.
Issues: Whether or not petitioner has legal standing?
Whether or not the President’s factual determination of the necessity of calling
the armed forces is subject to judicial review?
Held:
First Issue: No locus standi. The petitioner failed to sufficiently show that it is in possession of the requisites of standing to raise the issues in the petition. Locus standi has been defined as personal & substantial interest in the case such that the party has sustained or will sustain direct injury as result of the challenged act. In this case, IBP primarily anchors its standing on its alleged responsibility to uphold the constitution. The mere invocation by the IBP of its duty to preserve the rule of law & nothing more, while undoubtedly true, is not sufficient to clothed it w/ standing.
That is too general, an interests that is shared by other groups & the whole citizenry. IBP’s fundamental purpose that is to elevate the standards of the law profession & improve the administration of justice, cannot be affected by the deployment of the Marines.
Second Issue:
The power of judicial review is set forth in Section 1, Article VIII of the Constitution, to wit:
Section 1. The judicial power shall be vested in one Supreme Court and in such lower courts as may be established by law.
Judicial power includes the duty of the courts of justice to settle actual controversies involving rights which are legally demandable and enforceable, and to determine whether or not there has been grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government.
When questions of constitutional significance are raised, the Court can exercise its power of judicial review only if the following requisites are complied with, namely: (1) the existence of an actual and appropriate case; (2) a personal and substantial interest of the party raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest opportunity; and (4) the constitutional question is the lis mota of the case.
