Bagong Alyansan Makabayan v Zamora

342 SCRA 739, April 11, 2002

Facts:
The court is confronted for resolution in the instant consolidated petitions for certiorari and
prohibition issues relating to the Visiting Forces Agreement borne by the forged agreement
between the Philippines and the United States.
Issues raised by the petitioners revolve around the issues affected by the VFA.

Issue:
Whether or not petitioners posses legal standing to question legality and constitutionality of the
Visiting Forces Agreement.

Ratio Decidendi:
Petitioners failed to show the satisfaction of the court that they really have sustained or are in
danger of sustaining any direct injury as a result of the enforcement of the VFA. The suit
brought up to the court as a taxpayer’s suit cannot also be invoked. The issued does not involve
the exercise of congress of its taxing or spending powers or the act complained of directly
involves the illegal disbursement of public funds derived from taxation. The benefit or injury by
the judgment or entitlement to the avails of the suit as a real party in interest is held lacking by
the court. Clearly, no public funds raised by taxation are involved in this case and the absence
of any allegation by petitioners that public funds are being misspent or illegally expended makes
the petitioners lack the necessary legal standing for judicial review.
Petitioners-legislators do not also possess legal standing since a clear showing of any direct
injury as a result of impairment of legislative power is missing.
The petitioner, IBP lacks the legal capacity to bring suit since there was no board resolution that
authorized the National President to commence the present action.
However, the court entertained the case and applied the exception due to the transcendental
importance the public demanded on the case. The court thus relaxed the standing requirements
and allowed the suit to prosper even where direct injury to the party claiming the right to judicial
review is missing.
The focal point of the case is with regards to the senate’s exercise of its constitutional power to
concur the VFA. The petitioners allege that the President acted with grave abuse of discretion
for having signed and approved the agreement. But the Supreme Court upheld that the
president had the power to enter into treaties or international agreements as vested by the
Constitution. The president’s action squarely falls within the sphere of his constitutional powers
and thus may not be validly struck down. In this lawful exercise of his vast executive and
diplomatic powers, the petitions are dismissed.