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WIGBERTO E. TAÑADA v. EDGARDO ANGARA

FACTS:

On April 15, 1994, then Secretary of the Department of Trade and Industry, Rizalino Navarro, representing the Philippine government, signed the Final Act Embodying the Results of the Uruguay Round of Multilateral Negotiations in Marrakesh, Morocco. By doing so, Secretary Navarro agreed to submit the WTO Agreement for approval and to adopt the Ministerial Declarations and Decisions. Subsequently, the Philippine Senate received letters from President Fidel V. Ramos on August 12 and 13, 1994, submitting the Uruguay Round Final Act, the WTO Agreement, Ministerial Declarations, and Understanding on Commitments in Financial Services for Senate concurrence. On December 9, 1994, President Ramos certified the necessity of immediate adoption of Senate Resolution No. 1083, concurring in the ratification of the WTO Agreement. Following this, on December 14, 1994, the Philippine Senate adopted Resolution No. 97, concurring in the ratification of the WTO Agreement. On December 16, 1994, President Ramos signed the Instrument of Ratification, formally ratifying the WTO Agreement. The petitioners subsequently filed a motion to nullify the Senate's concurrence, arguing that the WTO Agreement demands the Philippines to place foreign nationals and products on equal footing with Filipinos, thus intruding on constitutional powers and impairing national economic policy as mandated by the 1987 Constitution. The petitioners contend that this violates the Constitution's call for a self-reliant and independent national economy controlled by Filipinos as well as the preferential use of Filipino labor, materials, and goods.

ISSUES:

  1. Does the petition present a justiciable controversy, or does it involve a political question beyond the jurisdiction of the Court?

  2. Do the provisions of the WTO Agreement and its three annexes contravene Sections 19, Article II, and Sections 10 and 12, Article XII of the Philippine Constitution?

  3. Do the provisions of the WTO Agreement and its annexes limit, restrict, or impair the exercise of legislative power by Congress?

  4. Do the provisions of said Agreement and its annexes unduly impair or interfere with the exercise of judicial power by the Court in promulgating rules on evidence?

  5. Was the concurrence of the Senate in the WTO Agreement and its annexes sufficient and valid, considering that it did not include the Final Act, Ministerial Declarations and Decisions, and the Understanding on Commitments in Financial Services?

RULING:

  1. Justiciable Controversy The petition presents a justiciable controversy as it seriously alleges that an act of the Philippine Senate infringes the Constitution, thus requiring judicial review. The Supreme Court has the jurisdiction to settle such disputes.

  2. WTO Agreement vs. Philippine Constitution The provisions of the WTO Agreement do not contravene sections 19, Article II, and sections 10 and 12, Article XII of the Constitution. The Agreement and its annexes align with the constitutional mandate of economic nationalism while considering equality and reciprocity in trade relations.

  3. Legislative Power The WTO Agreement does not unduly limit, restrict, or impair the exercise of legislative power by Congress. Congress retains its authority to legislate, conforming to the obligations under international treaties, which is in itself a constitutional principle.

  4. Judicial Power The provisions of the WTO Agreement do not unduly impair or interfere with the exercise of judicial power by the Supreme Court in promulgating rules on evidence. The adjustments required are reasonable and reciprocally beneficial under the international agreements.

  5. Senate Concurrence The Senate's concurrence in the WTO Agreement and its annexes was valid and sufficient. The WTO Agreement's requirement for members to ensure compliance with its provisions is within constitutional bounds, and the broader context of international cooperation and reciprocity justifies the Senate's action.

PRINCIPLES:

  • Justiciable Controversy Courts have the duty to settle disputes involving alleged infringements of the Constitution.

  • Economic Nationalism vs. International Trade The Constitution mandates a bias in favor of Filipino interests but does not preclude international trade based on equality and reciprocity.

  • Legislative Power and Treaty Obligations Legislative powers are not unduly restricted by international agreements, as treaties inherently involve some sovereignty compromises for mutual benefits.

  • Judiciary's Rule-Making Authority Adjustments in local laws to align with international treaties do not unduly infringe on the judiciary's authority to promulgate rules of evidence.

  • Senate's Concurrence and International Treaties The Senate's concurrence in international agreements must meet constitutional mandates, acknowledging the importance of international cooperation and legal obligations.

  • Doctrine of Incorporation International law principles, including the performance of treaty obligations in good faith (pacta sunt servanda), are an intrinsic part of domestic law.