Biraogo vs. Philippine Truth Commission of 2010, G.R. No. 192935

An Executive Order issued by the President created the Philippine Truth Commission (PTC), an investigative body that can gather and assess evidence of graft and corruption and make recommendations. Along with certain legislators, a "taxpayer" filed a petition questioning the Executive Order. Petitioners contend that the Executive Order violates the separation of powers for being a usurpation of legislative power. Moreover, it illegally amends the constitution when it vested the PTC with quasi-judicial powers duplicating, if not superseding, those of the Office of the Ombudsman. 

Respondents questioned the petitioners' standing. In particular, the "taxpayer" has no standing since the funds used for the creation and operation of the PTC are to be taken from funds already appropriated by Congress. The court noted that standing to impugn the validity of a statute requires a personal and substantial interest in the case, such that he has sustained or will sustain a direct injury as a result. However, "the rule of standing is a matter of procedure, hence, can be relaxed for nontraditional plaintiffs like ordinary citizens, taxpayers and legislators when the public interest so requires, such as when the matter is of transcendental importance, of overreaching significance to society, or of paramount public interest."