CASE NO.

03
Metropolitan Manila Development Authority v. Concerned Residents of
Manila Bay
G.R. Nos. 171947-48 February 15, 2011

Facts:

This case involves a petition filed by the Metropolitan Manila Development

Authority (MMDA) and various government agencies against the Concerned
Residents of Manila Bay. The petitioners sought to overturn the decision of the Court
of Appeals and the Regional Trial Court, which ordered them to clean up and
rehabilitate Manila Bay.

The Supreme Court, in its decision on December 18, 2008, affirmed the lower court's
ruling but with modifications. The court ordered the government agencies to clean
up, rehabilitate, and preserve Manila Bay, and restore its waters to a level fit for
swimming and other recreational activities. The court also directed the agencies to
implement their respective plans and coordinate with other government departments
and agencies to ensure the successful implementation of the rehabilitation plan.

Issue:

The main issue raised in the case is whether the Supreme Court has the authority to
issue such directives and whether it constitutes an encroachment on the executive
powers of the President and the local government units (LGUs).

Ruling:

The Supreme Court ruled that the Resolution indeed constitutes an intrusion of the
Judiciary into the exclusive domain of the Executive. It emphasized that the
Constitution vests executive power in the President and grants the President control
over executive departments, bureaus, and offices. The Court also noted that its
members are prohibited from performing quasi-judicial or administrative functions.
Therefore, the directives in the Resolution, which involve administrative matters and
supervision of government agencies and LGUs, exceed the Court's jurisdiction and
violate the principle of separation of powers.

Ratio:

The Court explained that the Supreme Court should only exercise judicial power and
should not assume any duty that does not pertain to the administering of judicial
functions. It cited previous cases that emphasized the need for the Court to confine
itself to its judicial functions and not to perform non-judicial functions.

The Court further emphasized the importance of respecting the boundaries between
the three branches of government and refraining from assuming or being compelled
to perform non-judicial functions. It held that the Resolution constitutes a judicial
encroachment on executive functions and violates the system of separation of
powers.
Summary:

In summary, the Supreme Court affirmed the lower court's ruling ordering the
government agencies to clean up and rehabilitate Manila Bay. However, the Court
ruled that the Resolution issued by the Court, which contained directives for various
government agencies and LGUs, exceeded its jurisdiction and violated the principle
of separation of powers. The Court emphasized the importance of respecting the
boundaries between the three branches of government and refraining from assuming
non-judicial functions.