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232 - Joya V PCGG

This case summary discusses the doctrine of standing to challenge in judicial proceedings. It provides that a party must have a personal and substantial material interest in a case to have standing, such that they will sustain direct injury from the governmental act being challenged. It notes that mandamus suits can proceed when a public right in the constitution is being enforced or a public duty is being breached. Taxpayer suits are also allowed when public funds are being misapplied in administering an unconstitutional act. The document then summarizes the key facts, issues and ruling of the 1993 case Joya v. PCGG regarding whether petitioners had legal standing to challenge the sale of paintings and silverware claimed to be former President Marcos' ill-gotten wealth.

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77 views1 page

232 - Joya V PCGG

This case summary discusses the doctrine of standing to challenge in judicial proceedings. It provides that a party must have a personal and substantial material interest in a case to have standing, such that they will sustain direct injury from the governmental act being challenged. It notes that mandamus suits can proceed when a public right in the constitution is being enforced or a public duty is being breached. Taxpayer suits are also allowed when public funds are being misapplied in administering an unconstitutional act. The document then summarizes the key facts, issues and ruling of the 1993 case Joya v. PCGG regarding whether petitioners had legal standing to challenge the sale of paintings and silverware claimed to be former President Marcos' ill-gotten wealth.

Uploaded by

Maria Lourdes Dator
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Joya v.

PCGG (1993)

Doctrine:
Standing to challenge is one of the 4 requisites for judicial inquiry. It is enshrined in the Rules of
Court. Legal standing is defined as a personal and substantial material interest in the case such
that the party has sustained or will sustain direct injury as a result of the governmental act that
is being challenged.

A mandamus suit succeeds when the public right to be enforced and the concomitant duty of the
state are clearly stated in the Constitution.

A taxpayer's suit prospers when the governmental acts being questioned involve disbursement
of public funds upon the theory that the expenditure of public funds by an officer of the state for
the purpose of administering an unconstitutional act constitutes a misapplication of such funds,
which may be enjoined at the request of a taxpayer.

Summary:
This case originates from a Special Civil Action for Prohibition and Mandamus with Prayer for
Preliminary Injunction and/or Restraining Order, filed by Dean Jose Joya, et al. against the
PCGG. Joya et al. seek to enjoin the PCGG from proceeding with the auction of paintings and
antique silverware, allegedly part of former President Marcos’ ill-gotten wealth. The PCGG
sought to sell the items through Christie’s. Despite the COA’s findings against the legality of the
sale, it proceeded as scheduled since no injunction was granted by the SC. The SC decided
against Joya et al., dismissing the petition.

Issues: W/N petitioners have legal standing to file the instant petition

Ruling: No.
GR: The Court will exercise its power of judicial review only if the case is brought before it by a
party who has the legal standing to raise the constitutional or legal question.
EXCEPTIONS:
 when a citizen brings a case for mandamus to procure the enforcement of a public
duty for the fulfillment of a public right recognized by the Constitution
 when a taxpayer questions the validity of a governmental act authorizing the
disbursement of public funds

In the instant case, Joya et al. are not the proper parties to sue, since the items are not of the
public dominion, nor protected by the Constitution nor the Cultural Properties Preservation and
Protection Act. The paintings were donated to the Metropolitan Museum of Manila Foundation,
so the ownership pertains to the foundation or its members. As to the silverware, these were
given as gifts to the Marcoses during their wedding anniversary, an occasion which is private in
nature. The true owners are the ones who have the standing to sue. This case cannot be treated
as a suit for mandamus since no right is sought to be enforced. Neither can it be a taxpayer’s suit
since there is no disbursement of public funds to speak of.

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