FACTS:

The case involves the implementation of a decision by the Supreme Court of the Philippines regarding the cleanup and preservation of Manila Bay. The government agencies involved were ordered to carry out various tasks to restore the water quality of the bay. A committee was created to monitor the activities of the agencies and evaluate their progress. The agencies submitted periodic reports detailing their compliance with the judgment. The submission of these reports is considered part of the execution stage of the final decision. Upon full satisfaction of the judgment, a final return of the writ shall be made to the court.

In another case, a petitioner filed a petition for the writ of habeas corpus, seeking the release of respondents who were detained without a warrant of arrest or legal basis. The trial court granted the petition, but the respondents claimed they had already been released. The Supreme Court clarified that the writ of habeas corpus is used to determine the legality of detention and secure release if found unlawful. The return of the writ, which includes the facts and circumstances surrounding the detention, must be verified by the person who made it. The petitioner disputed the respondents' claim of release and requested the parties to file their verified returns to clarify the issue.

ISSUES:

1. Whether the issuance of subsequent resolutions by the Court after the finality of its Decision constitutes an encroachment over the powers and functions of the Executive Branch.

RULING:

1. The issuance of subsequent resolutions by the Court does not constitute an encroachment over the powers and functions of the Executive Branch. This action is merely an exercise of judicial power under Article VIII of the Constitution since the execution of its Decision is an integral part of the adjudicative function of the Court. No agency questioned the Court's power to implement the Decision or raised any issue of alleged encroachment.

PRINCIPLES:

• Judicial Power and Continuing Mandamus The Court’s power under Article VIII of the Constitution includes the continuing jurisdiction to ensure the execution of its final judgment, especially in environmental cases.

• Execution of Judgment Rule 39, Section 47 of the Rules of Court states that a judgment includes what appears to have been adjudged and those matters necessarily included or necessary thereto.

• Environmental Compliance Reporting Sections 7 and 8, Rule 8 of the Rules of Procedure for Environmental Cases require respondents to submit periodic reports detailing progress and execution of the judgment, allowing the court to monitor compliance through itself or an appropriate agency.