The Supreme Court ruled that its consideration of the appeal filed by Oceana Philippines International, Pablo R. Rosales, and Ronalda P. Reyes (collectively, Oceana et al.) shall be limited only to the propriety of the denial of their Motion to Intervene, and that the Court cannot rule on the issues they raised regarding the June 1, 2021 Decision of the Regional Trial Court (RTC).
The Case
The case involves consolidated petitions docketed as G.R. Nos. 256282, 256559, and 257049. G.R. No. 257049, a Petition for Review on Certiorari filed under Rule 45 of the Rules of Court, challenged the Orders of the RTC dated May 25, 2021 and June 23, 2021, which respectively denied the Motion to Intervene and the Motion for Reconsideration filed by Oceana et al. That petition likewise assailed the June 1, 2021 Decision of the RTC which declared FAO No. 266 unconstitutional.
The Court consolidated G.R. No. 256559 with G.R. No. 256282 on November 18, 2021, and G.R. No. 257049 with G.R. No. 256282 on December 7, 2021.
On February 25, 1998, Republic Act No. 8550, otherwise known as The Philippine Fisheries Code of 1998, was enacted. On February 27, 2015, Republic Act No. 10654 was passed to amend Republic Act No. 8550, to strengthen the prevention, deterrence, and elimination of illegal, unreported, and unregulated fishing.
On October 5, 2018, the Department of Agriculture (DA), through the Bureau of Fisheries and Aquatic Resources (BFAR), issued FAO No. 260. More than two years later, on October 12, 2020, the DA, through the BFAR, issued FAO No. 266 to update FAO No. 260, removing the limitation of the rules to vessels targeting straddling and highly migratory fish stocks, so the rules would apply to all commercial Philippine-flagged fishing vessels.
The Issue
As the Court framed it, the ruling on the Petition of Oceana et al. shall be limited only to the propriety of the denial of their Motion to Intervene, pursuant to the pronouncement in Foster-Gallego v. Spouses Galang that the intervenor, as a petitioner in an appeal, can question only the order denying the intervention, not the decision itself.
The Ruling
The Court held that although the May 25, 2021 Order of the RTC was an interlocutory order, the merits of the case had nevertheless been adjudicated by the same court in its June 1, 2021 Decision. Following the ruling in Gallego, the Court gave due course to Oceana et al.'s appeal via Petition for Review on Certiorari, but limited its ruling to the question of whether the RTC correctly denied Oceana et al.'s Motion to Intervene. The Court stated it cannot rule on the issues raised by Oceana et al. regarding the June 1, 2021 Decision.
The Court noted that Oceana et al. never became a party to the Petition for Declaratory Relief, a point conceded during the Oral Arguments on October 10, 2023. The Court found that the Rules of Procedure for Environmental Cases (RPEC) is not applicable in this case because it covers only actions that involve enforcement or violations of environmental and other related laws, rules and regulations.
By the Numbers
- G.R. Nos. 256282, 256559, and 257049 — the consolidated cases
- February 25, 1998 — enactment of Republic Act No. 8550
- February 27, 2015 — passage of Republic Act No. 10654
- October 5, 2018 — issuance of FAO No. 260
- October 12, 2020 — issuance of FAO No. 266
- January 22, 2021 — RTC Order granting the application for injunction
- May 25, 2021 and June 23, 2021 — RTC Orders denying the Motion to Intervene and the Motion for Reconsideration
- June 1, 2021 — RTC Decision declaring FAO No. 266 unconstitutional
- PHP 3.5 million — the cash or surety bond required by the RTC
- October 10, 2023 — the Oral Arguments
The Court's Reasoning
The Court explained that under the doctrine of hierarchy of courts, Oceana et al.'s petition should have been filed with the Court of Appeals. However, the Court cited a peculiar instance it could not ignore: by the time the Motion for Reconsideration was denied on June 23, 2021, the RTC had already rendered the June 1, 2021 Decision and decided with finality on the merits of the Petition for Declaratory Relief. By June 25, 2021, or merely two days after the denial of the Motion for Reconsideration, the Republic had already filed its Petition for Review on Certiorari with the Court to assail the June 1, 2021 Decision.
The Court reasoned that had Oceana et al. assailed the denial through a Rule 65 Petition with the Court of Appeals and secured a favorable decision, there would be no more case before the RTC that they could intervene in, since the case was already before the Court via a Petition for Review on Certiorari under Rule 45.
In denying the Motion to Intervene, the RTC had ruled that the movant-intervenors could not be considered real parties with legal interests in the subject matter of the litigation, and that the party who can best defend its position is the government agency involved in the issuance of the order.
Source: Supreme Court Decision in G.R. Nos. 256282, 256559, and 257049.
This report summarizes a public Supreme Court decision and is not legal advice.