Resident Marine Mammals of the Protected Seascape Tañon Strait, et al. vs. Secretary Angelo Reyes, G.R. No. 180771 (Philippines)

The case involved two consolidated petitions challenging the validity of the environmental compliance certificate and service contract granted to Japan Petroleum Exploration Co., Ltd. The certificate and contract were for the exploration, development, and exploitation of petroleum resources within a protected seascape.

The petitioners comprised (i) the resident marine mammals of the Tañon Strait, such as toothed whales, dolphins, porpoises, and two natural persons called “the Stewards”; and (ii) the Central Visayas Fisherfolk Development Center. 

The petitioners protested the adverse ecological impact of the oil exploration activities, including a 50%–70% reduction in fish catch. They argued that the environmental compliance certificate was invalid because Japan Petroleum Exploration did not comply with Philippine Environmental Impact Assessment system requirements. The court discussed the challenges that animal rights advocates and environmentalists face in protecting animals and inanimate objects. Traditional rules of standing require advocates to show that they are real parties in interest, which is challenging when the advocates suffer no direct harm or injury. Nevertheless, procedural rules only allow natural and juridical persons to bring lawsuits. However, the court noted that the landmark 2010 Philippine Rules of Procedure for Environmental Cases allow for citizen suits on the principle that humans are stewards of nature. As the rules recognize legal standing for stewards of nature, the court reasoned there was no need to grant standing to the resident marine mammals.