FACTS:

This case involves a Petition for Review on Certiorari filed by Mayor Tomas R. Osmeña, seeking to reverse the Decision and Resolution of the Court of Appeals. The Department of Environment and Natural Resources (DENR) had issued an Environmental Compliance Certificate (ECC) in 1993 for the Inayawan landfill, but in 2011, the Cebu City Local Government decided to close the landfill and use a privately operated site for waste disposal. The landfill was officially closed in 2015.

In 2016, Mayor Osmeña's administration sought to temporarily reopen the Inayawan landfill, with the DENR not objecting as long as commitments were complied with and monitoring was conducted. The landfill was officially reopened in July 2016. However, on September 2, 2016, the DENR's Environmental Management Bureau (EMB) issued a Notice of Violation and Technical Conference to Mayor Osmeña, citing violations of the ECC. The Department of Health also recommended the immediate closure of the landfill due to sanitary and environmental concerns.

In response, on September 23, 2016, the respondent filed a petition for writ of kalikasan with the Court of Appeals, arguing that the landfill's operation caused environmental damage and violated environmental laws. The Court of Appeals granted the petition, ordering Mayor Osmeña to permanently cease and desist from dumping garbage at the landfill and to continue its rehabilitation. The Court of Appeals denied Mayor Osmeña's motion for reconsideration.

Mayor Osmeña then filed a petition before the Supreme Court, contending that the 30-day prior notice requirement for citizen suits under R.A. 9003 and R.A. 8749 was not complied with. The Supreme Court, however, held that the petition was without merit and ruled that the notice requirement was not necessary in this case.

ISSUES:

1. Whether or not the 30-day prior notice requirement for citizen suits under R.A. 9003 and R.A. 8749 is applicable in a petition for a writ of kalikasan.

2. Whether the closure of the Inayawan landfill is warranted due to environmental violations committed by the City Government.

3. Whether the writ of kalikasan should be granted to permanently cease and desist from dumping or disposing of garbage at the Inayawan landfill and to continue its rehabilitation.

4. Whether or not the Court of Appeals erred in finding that the trial court committed grave abuse of discretion in refusing to let the petitioner present evidence to support her defense.

5. Whether or not the Court of Appeals erred in ordering the petitioner's acquittal on the ground of reasonable doubt.

RULING:

1. The prior 30-day notice requirement for citizen suits under R.A. 9003 and R.A. 8749 is inapplicable in a petition for a writ of kalikasan. The Court has the discretion to accept petitions brought directly before it. The requirements for the grant of the privilege of the writ of kalikasan were sufficiently established by the respondent.

2. The Court affirmed the decision of the Court of Appeals, granting the privilege of the writ of kalikasan and ordering the City Mayor of Cebu to permanently cease and desist from dumping or disposing of garbage at the Inayawan landfill and to continue its rehabilitation.

3. No, the Court of Appeals did not err in finding that the trial court committed grave abuse of discretion. It is settled that the presentation of evidence is a matter within the sound discretion of the trial court. However, such discretion must be exercised with caution and must not be capriciously used to deny a party the opportunity to prove her case.

4. No, the Court of Appeals did not err in ordering the petitioner's acquittal on the ground of reasonable doubt. The appellate court correctly observed that the prosecution failed to establish the guilt of the petitioner beyond reasonable doubt. The petitioner's defense, coupled with the doubts surrounding the testimonies of the witnesses for the prosecution, created reasonable doubt in the case.

PRINCIPLES:

• The writ of kalikasan is an extraordinary remedy that provides stronger protection for environmental rights and aims to provide a speedy and effective resolution of cases involving the violation of the constitutional right to a healthful and balanced ecology that transcends political and territorial boundaries.

• To avail of the extraordinary remedy of a writ of kalikasan, the following requisites must be present: (1) actual or threatened violation of the constitutional right to a balanced and healthful ecology; (2) violation arises from an unlawful act or omission of a public official or employee, or private individual or entity; and (3) violation involves or will lead to an environmental damage of such magnitude as to prejudice the life, health, or property of inhabitants in two or more cities or provinces.

• The gravity of environmental damage sufficient to grant the writ of kalikasan is to be decided on a case-to-case basis but must be sufficiently grave in terms of the territorial scope of the damage.

• The Court has discretionary power to accept petitions for a writ of kalikasan brought directly before it.

• Compliance with environmental laws and regulations is necessary to prevent potential environmental harm.

• Recommendations and findings of administrative agencies can be considered in deciding cases that require technical knowledge and expertise.

• The presentation of evidence is a matter within the sound discretion of the trial court.

• Discretion of the trial court must not be capriciously used to deny a party the opportunity to prove her case.

• The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.

• Reasonable doubt is that doubt engendered by an investigation of the whole proof and an inability, after such investigation, to let the mind rest easy upon the certainty of guilt.