GR no. 97787 Anti-Graft League of the Philippines vs.

CA
Ponente: J.Romero
FACTS
- President Marcos in 1975 issued PD 674 establishing Technological Colleges of
Rizal. It made the Provincial Board purchase four parcels of land from Ortigas &
Co. Ltd. totaling 192,177 square meters at P110.00 per square meter.
- Land remained unused for 12 years, so the Board passed Resolution 87-205,
allowing Governor to sell the land. It was then sold to ValleyView Realty
Development Corp. for P700.00 per square meter or P134,523,900.00, of which
30,000,000 was downpayment.
- Ortigas filed for rescission of contract because Board violated its terms (that land
wiould be used to build Colleges)
- In 1988, Board filed for rescission of deed of sale with Valley View because land
was sold at exceedingly low price
- Valley View filed case against Province of Rizal for specific performance and
damages, which was dismissed. Downpayment was returned.
- Province agreed to reconvey 4 parcels of land to Ortigas at 2,250 per square
meter, payable in two years with 14% interest rate.
- Petitioners AGLP is a non-stock, non-profit organization that protects theinterest
of the republic, its instrumentalities, political subdivisions, constituents against
abuse of its public officials
- They claim instant petition for certiorari. They say this is a taxpayers suit
because Provincial Board of Rizal illegally disbursed public funds
DOCTRINE
- Locus standi ; whether petitioners have legal standing to file the case or not
ISSUE
- W/N this is a taxpayers suit
HELD
- It is not a taxpayers suit.
RATIO DECIDENDI
- There are two requirements for a petition to be a taxpayers suit:
o Public funds are disbursed by political subdivision or instrumentality, and
in doing so violates a law
o Petitioner is directly affected by the act
- Petitioners would be affected as taxpayers by illegal use of money, but since
unlawful spending cannot be proven, the transaction cannot be questioned.
Petitioners wont be affected by contract. Petitioners have no legal standing to
sue