The Supreme Court required government agencies to maintain the prescribed water quality standards of Manila Bay even in the absence of a specific pollution accident. The Court’s directives focused on three main areas: (i) prevention, control, and protection; (ii) prosecution and sanctions; and (iii) rehabilitation. To ensure compliance with the Court’s directives, it used the principle of continuing mandamus, which was not codified in Philippine statutes at the time of the case’s promulgation.