SOUTHERN HEMISPHERE ENGAGEMENT NETWORK, INC.

vs ANTI-TERRORISM COUNCIL
G.R. No. 178552 October 5, 201

Six petitions challenging the constitutionality of Republic Act No. 9372 (RA 9372), "An Act to
Secure the State and Protect our People from Terrorism," otherwise known as the Human
Security Act of 2007

In constitutional litigations, the power of judicial review is limited by four exacting requisites,
viz:
(a) there must be an actual case or controversy;
An actual case or controversy means an existing case or controversy that is
appropriate or ripe for determination, not conjectural or anticipatory, lest the decision of
the court would amount to an advisory opinion.

(b) petitioners must possess locus standi;

A party who assails the constitutionality of a statute must have a direct and
personal interest. It must show not only that the law or any governmental act is invalid,
but also that it sustained or is in immediate danger of sustaining some direct injury as a
result of its enforcement. Requisites:
1. It has personally suffered some actual or threatened injury as a result of the
allegedly illegal conduct of the government,
2. The injury is fairly traceable to the challenged action, and
3. The injury is likely to be redressed by a favorable action;

(c) the question of constitutionality must be raised at the earliest opportunity; and
(d) the issue of constitutionality must be the lis mota of the case.