04/02/2020
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Vague propositions that the implementation of the assailed orders will work injustice
and violate the rights of its members cannot clothe MDOI with the requisite
standing. Neither would its status as a "people's organization" vest it with the legal
standing to assail the validity of the executive orders.[14]
La Bugal-B'laan Tribal Association, Inc. v. Ramos,[15] which MDOI cites in support of
its claim to legal standing, is inapplicable as it is not similarly situated with the
therein petitioners who alleged personal and substantial injury resulting from the
mining activities permitted by the assailed statute. And so is Cruz v. Secretary of
Environment and Natural Resources,[16] for the indigenous peoples' leaders and
organizations were not the petitioners therein, who necessarily had to satisfy the
locus standi requirement, but were intervenors who sought and were allowed to be
impleaded, not to assail but to defend the constitutionality of the statute.
Moreover, MDOI raises no issue of transcendental importance to justify a relaxation
of the rule on legal standing. To be accorded standing on the ground of
transcendental importance, Senate of the Philippines v. Ermita[17] requires that the
following elements must be established: (1) the public character of the funds or
other assets involved in the case, (2) the presence of a clear case of disregard of a
constitutional or statutory prohibition by the public respondent agency or
instrumentality of government, and (3) the lack of any other party with a more
direct and specific interest in raising the questions being raised. The presence of
these elements MDOI failed to establish, much less allege.
Francisco, Jr. v. Fernando[18] more specifically declares that the transcendental
importance of the issues raised must relate to the merits of the petition.
This Court, not being a venue for the ventilation of generalized grievances, must
thus deny adjudication of the matters raised by MDOI.
Now, on AMIN's position. AMIN charges the Executive Department with transgression
of the principle of separation of powers.
Under the principle of separation of powers, Congress, the President, and the
Judiciary may not encroach on fields allocated to each of them. The legislature is
generally limited to the enactment of laws, the executive to the enforcement of laws,
and the judiciary to their interpretation and application to cases and controversies.
The principle presupposes mutual respect by and between the executive, legislative
and judicial departments of the government and calls for them to be left alone to
discharge their duties as they see fit.[19]
AMIN contends that since the DAR, PCUP and NCIP were created by statutes,[20]
they can only be transformed, merged or attached by statutes, not by mere
executive orders.
While AMIN concedes that the executive power is vested in the President [21] who,
as Chief Executive, holds the power of control of all the executive departments,
bureaus, and offices, [22] it posits that this broad power of control including the
power to reorganize is qualified and limited, for it cannot be exercised in a manner
contrary to law, citing the constitutional duty [23] of the President to ensure that the
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