No, no, no. I am not referring to court employees, lawyers or judges. Animals really sued in court. It might sound absurd, but an actual case where animals were the complainants was decided by the Supreme Court in 2015! Last week’s article was about minors suing the government to protect and preserve the environment and this time- animals. In the future, computers or robots? We cannot say for sure. In the past, it was inconceivable for animals to become complainants or plaintiffs in a court case. Who knows in the near future computers or robots might be allowed to sue in court much like animals. The traditional concept of cases is that involves two parties who are persons or group of persons seeking the determination of the court on an issue or controversy between them.
Resident Mammals vs. Reyes
On 17 December 2007 a petition was filed by “Resident Marine Mammals of the Protected Seascape Tanon Strait, E.G., Toothed Whales, Dolphins, Porpoises, and Other Cetacean Species, Joined in and Represented Herein by Human Beings Gloria Estenzo Ramos and Rose-Liza Eisma-Osorio, in their Capacity as Legal Guardians of the Lesser life-forms and as Responsible Stewards of God’s Creation” (G.R. No. 180771, April 21, 2015) against the Secretary of the Department of Environment and Natural Resources (DENR) et., al. seeking to enjoin the latter in implementing an oil exploration service contract at Tanon Strait. In gist, the petition alleged that the oil exploration being conducted on the strait will destroy the habitat of the “petitioner mammals” hence must be stopped. Among other issues, the respondents countered and claimed that the petitioner do not have the standing (locus standi) to file the petition “because Section 1, Rule 3 of the Rules of Court requires parties to an action to be either natural or juridical persons”. The guardians cannot also file the case because “they are representing animals, which cannot be parties to an action”. The petitioner argued that “…that they have the legal standing to file this action since they stand to be benefited or injured by the judgment in this suit” and also cited Oposa vs Factoran Jr. (discussed last week) to bolster their position.
The Resident Mammals Can Sue
Indeed the Rules of Court only provides who may be parties to a case- “Only natural or juridical persons, or entities authorized by law may be parties in a civil action” (Sec. 1, Rule 3). Animals are not included here. When it comes to cases involving the environment, the Supreme Court has a more relaxed approach. It declared that the Resident Mammals have standing and therefore can pursue the case as petitioners. Years after the filing of the petition the SC promulgated the Rules of Procedure for Environmental Cases (A.M. No. 09-6-8-SC, effective April 29, 2010) which provides that a case may be filed by any “Filipino citizen in representation of others, including minors or generations yet unborn, may file an action to enforce rights or obligations under environmental laws” (Sec. 5). The SC also said that Citizen Suits may be filed “on the principle that humans are stewards of nature”. Although the case was filed way before the effectivity of the Rules of Procedure for Environmental Cases, it is deemed applicable here because of rules of procedure “may be retroactively applied to actions pending and undetermined at the time of their passage and will not violate any right of a person who may feel that he is adversely affected, inasmuch as there is no vested rights in rules of procedure.” In the end, although petitioners have been declared to have the capacity to initiate the petition, the exploration was already stopped by the company years before the decision came out but the case has already enriched our jurisprudence by providing pronouncement as to the issue or legal standing.