139 for violations of environmental laws. The Court, in Metropolitan v. Concerned Residents of Manila Bay affirmed that the need to give animals (in this case resident marine mammals of the Tañon Strait) “legal standing has been eliminated by our Rules [for Environmental Cases], which allow any Filipino citizen, as a steward of nature, to bring a suit to enforce our environmental laws.” 601 The Rules of Procedure for Environmental Cases further provide that when there is a lack of full scientific certainty in establishing a causal link between human activity and environmental effect, the court shall apply the precautionary principle in resolving the case before it and the constitutional right of the people to a balanced and healthful ecology shall be given the benefit of the doubt.602 Section 2 of said rules provide for the standards to be used by courts in applying the precautionary principle to environmental cases, viz.: SEC. 2. Standards for application. —In applying the precautionary principle, the following factors, among others, may be considered: (1) threats to human life or health; (2) inequity to present or future generations; or (3) prejudice to the environment without legal consideration of the environmental rights of those affected. In Osmeña v. Garganera,603 the Supreme Court declared that while it has “jurisdiction and power to decide cases, [it] is not precluded from utilizing the findings and recommendations of the administrative agency on questions that demand the exercise of sound administrative discretion requiring the special knowledge, experience, and services of the administrative tribunal to determine technical and intricate matters of fact.”604 The court emphasized that the Writ of Kalikasan was designed to give stronger protection for environmental rights; provide speedy and effective resolution to cases involving violations of the right to a healthful and balanced ecology that transcends political and territorial boundaries; and to address the potentially exponential nature of large-scale ecological threats.605 others, including minors or generations yet unborn, may file an action to enforce rights or obligations under environmental laws. Upon the filing of a citizen suit, the court shall issue an order which shall contain a brief description of the cause of action and the reliefs prayed for, requiring all interested parties to manifest their interest to intervene in the case within fifteen (15) days from notice thereof. The plaintiff may publish the order once in a newspaper of a general circulation in the Philippines or furnish all affected barangays copies of said order.) 601 Resident Marine Mammals v. Reyes, G.R. No. 180771 (2015). 602 Rules of Procedure for Environmental Cases (Section 1, Rule 20, Evidence, Part V). 603 Osmena v. Garganera, G. R. No. 231164 (Mar. 20, 2018) [hereinafter Osmena v. Gargarena]. 604 Osmeña v. Garganera, citing West Tower Condominium Corporation v. First Philippine Industrial Corporation, 760 Phil. 304, 339 (2015). 605 See Segovia, et al., v. The Climate Change Commission, G.R. No. 211010 (Mar. 7, 2017), citing Osmeña v. Garganera.