Magallona vs. ErmitaKey Take-Away: The enactment of [RA 9522] allows an internationally-recognized delimitation of the breadth of the Philippines maritime zones and continental shelf. RA 9522 is therefore a most vital step on the part of the Philippines in safeguarding its maritime zones, consistent with the Constitution and our national interest.G.R. No. 187167. August 16, 2011Ponente: Carpio, J.

Facts:Petition:1. Certoriari and prohibition assailing the constitutionality of RA 9522 adjusting the countrys archipelagic baselines and classifying the baseline regime of nearby territoriesFactual Antecedents:1. In 1961, Congress passed RA 3046, demarcating the maritime baselines of the Philippines as an archipelagic State.2. In 1968, Congress passed RA 5446, correcting typographical errors and reserving the drawing of baselines around Sabah in North Borneo.3. In March 2009, Congress amended RA 3046 by enacting RA 9522 which complies with the terms of the United Nations Convention on the Law of the Sea (UNCLOS III) which the Philippines ratified on 27 February 1984.4. Petitioners, professors of law, law students, and a legislator, in their respective capacities as citizens, taxpayers, or x x x legislators assail the constitutionality of RA 9522.Statute Involved: RA 9522, complying with the terms of UNCLOS III, shortened one baseline, optimized the location of some basepoints around the Philippine archipelago and classified the Kalayaan Island Group (KIG) and the Scarborough Shoal as regimes of islands whose islands generate their own applicable maritime zones.Position of Petitioner: RA 9522 is unconstitutional because1. It reduces Philippine maritime territory and the reach of the states sovereign power in violation of Article 1 of the 1987 Constitution.2. It opens the countrys waters landward of the baselines to maritime passage by all vessels and aircrafts, undermining Philippine sovereignty and national security, contravening the countrys nuclear-free policy, and damaging marine resources, in violation of relevant constitutional policies. In addition, petitioners contend that RA 9522s treatment of the KIG as regime of islands results in the loss of a large maritime area and prejudices the livelihoods of subsistence fishermen. Also, petitioners attack RA 9522 by stating that it fails to reference either the Treaty of Paris or Sabah and it uses UNCLOS IIIs framework of regime of islands to determine the maritime zones of the KIG and Scarborough Shoal.Position of Respondent: Respondent officials raised threshold issues questioning1. The petitions compliance with the case or controversy requirement for judicial review grounded on the petitioners lack of locus standi.2. The propriety of the writs of certiorari and prohibition to assail the constitutionality of RA 9522. On the merits, respondents defended RA 9522 as the countrys compliance with the terms of UNCLOS III, preserving Philippine territory over the KIG and Scarborough Shoal. Respondents add that RA 9522 does not undermine the countrys security, environment and economic interests or relinquish the Philippines claim over Sabah. Respondents also question the normative force, under international law, of petitioners assertion that what Spain ceded to the United States under the Treaty of Paris were the islands and all the waters found within the boundaries of the rectangular area drawn under the Treaty of Paris.

Issue: Preliminarily1. Whether petitioners possess locus standi to bring this suit; and2. Whether the writs of certiorari and prohibition are the proper remedies to assail the constitutionality of RA 9522. On the merits, whether RA 9522 is unconstitutional.

Held Ratio: On the threshold issues, the Court holds that1. The petitioners possess locus standi to bring this suit as citizens. Only as citizens because petition alleges neither infringement of legislative prerogative nor misuse of public funds With constitutionally sufficient interest in the resolution of the case which raises issues of national significance necessitating urgent resolution2. The writs of certiorari and prohibition are proper remedies to test the constitutionality of RA 9522. When the Court exercises its constitutional power of judicial review, the writs of certiorari and prohibition are viewed as proper remedial vehicles to test the constitutionality of statutes and acts of other branches of government. On the merits, the Court holds that there is no basis to declare RA 9522 unconstitutional.1. RA 9522 is a statutory tool to demarcate the countrys maritime zones and continental shelf under UNCLOS III, not to delineate Philippine territory.2. RA 9522s use of the framework of regime of islands to determine the maritime zones of the KIG and Scarborough Shoal are not inconsistent with the Philippines claim of sovereignty over these areas.3. Statutory claim over Sabah retained under RA 5446 as RA 9522 did not repeal the prior.4. UNCLOS III and RA 9522 are not incompatible with the Constitutions delineation of internal waters since whether these are referred to as internal waters or as archipelagic waters, the Philippines exercises sovereignty over the body of water lying landward of the baselines, including the air space over it, and the submarine areas underneath.

Final Ruling:Petition is dismissed.