## Facts

- Minor plaintiffs, represented by their parents and joined by an environmental NGO, filed a class suit seeking to protect the right to a balanced and healthful ecology for their generation and future generations.
- The complaint sought (1) cancellation of existing timber license agreements (TLAs) and (2) an order directing the environment secretary to stop accepting, processing, renewing, or approving TLAs.
- Plaintiffs alleged that continued logging under TLAs caused widespread deforestation and impaired the country’s environmental life-support systems.
- Plaintiffs relied on constitutional provisions recognizing a right to health and a right to a balanced and healthful ecology, and asserted a theory of intergenerational responsibility.
- The trial court dismissed the case on grounds including lack of cause of action, lack of standing, and the political question doctrine.
- Plaintiffs filed a petition for certiorari, arguing the dismissal was grave abuse of discretion.

## Issues

1. Whether minors (and an environmental organization) have standing and a cause of action to sue to protect the constitutional right to a balanced and healthful ecology, including on behalf of future generations.
2. Whether challenges to executive action in issuing and administering TLAs present a justiciable controversy or are barred as political questions.
3. Whether the constitutional right to a balanced and healthful ecology is judicially enforceable despite its placement among constitutional principles and state policies.
4. Whether relief seeking cancellation of TLAs requires joinder of TLA holders as necessary or indispensable parties.

## Decision

- The court granted the petition, set aside the trial court’s dismissal, and remanded for further proceedings.
- The court held that the minor plaintiffs had standing to sue for themselves, for others of their generation, and for future generations based on intergenerational responsibility.
- The court held that the constitutional right to a balanced and healthful ecology is fundamental, self-executing, and enforceable in court, supporting a cause of action.
- The court held the case presented an actual controversy and was not barred by the political question doctrine; courts may review executive action for conformity with constitutional and statutory limits.
- The court directed that, because cancellation of TLAs would directly affect license holders, those holders must be joined, and plaintiffs should be allowed to amend the complaint to implead them.

## Legal Principles

- A constitutional right to a balanced and healthful ecology is a judicially enforceable right and may be treated as self-executing where stated in specific and operational terms.
- Environmental rights carry correlative duties on both the state and private actors to refrain from impairing ecological balance and to protect natural resources.
- Minors may have standing to bring a representative action for environmental protection on behalf of present and future generations under intergenerational responsibility.
- The presence of policy considerations does not bar judicial review where executive action is alleged to violate constitutional rights or exceed legal authority.
- When requested relief would directly affect the rights of identifiable third parties, due process requires joinder of necessary or indispensable parties before adjudication.

## Conclusion

The court reinstated the minors’ environmental class suit, recognizing enforceable constitutional environmental rights and intergenerational standing, rejecting political-question objections, and requiring joinder of affected timber license holders on remand.


Oposa v. Factoran, Jr., 224 S.C.R.A. 792 (Phil. 1993)