"Legal standing" or locus standi  refers to a personal and substantial interest

in a case such that the party has sustained or will sustain direct injury
because of the challenged governmental act. 15 The requirement of standing,
which necessarily "sharpens the presentation of issues," 16 relates to
the constitutional mandate that this Court settle only actual cases or
controversies. 17 Thus, generally, a party will be allowed to litigate only when
(1) he can show that he has personally suffered some actual or threatened
injury because 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.   (Tolentino v. Commission on Elections,
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G.R. No. 148334, [January 21, 2004], 465 PHIL 385-476)

It may also be contended that when the Court engages in categorical balancing to determine whether
speech is unprotected, it really arrays countervailing interests between the speaker and the listener. For
instance, in Soriano v. Laguardia where the Court upheld the suspension of a televangelist prone to
cursing on air, it ruled that the interest of protecting children television viewers trumped the preacher’s
1
expressive right. While the interest was framed as the state’s, in the final analysis, it really is no more
than the welfare of the audience itself which the state brings as parens patriae. And the expression,
insofar as its communicative value to the audience performs “no essential part of any exposition of ideas,
and are of such slight social value as a step of truth that any benefit that may be derived from them is
2
clearly outweighed by the social interest in order and morality.”

1
605 Phil. 43–193 (2009) aff’d 629 Phil. 262–304 (2010).
2
Id.