Tuesday, April 7, 2020

[CASE DIGEST] TANADA v. ANGARA (G.R. No. 118295)

FACTS

In 1994, the WTO Agreement was signed by the Philippines through the DTI Secretary, and then later ratified by then President Fidel Ramos with the concurrence of the Senate.

In the same year, a Rule 65 petition was filed seeking to assail the Senate’s ratification of the WTO Agreement for violating the mandate of the 1987 Constitution to develop a self­reliant and independent national economy effectively controlled by Filipinos, to give preference to qualified Filipinos, and to promote the preferential use of Filipino labor, domestic materials, and locally produced goods.

RULING




The Court ruled for the State.

By their inherent nature, treaties really limit or restrict the absoluteness of sovereignty. By their voluntary act, nations may surrender some aspects of their state power – police power, eminent domain, and taxation -- in exchange of greater benefits granted by or derived from a convention or pact.

The WTO Agreement is also not violative of the Constitution because the constitutional policy of a “self­reliant and independent national economy” does not necessarily rule out the entry of foreign investments, goods, and services. It contemplates neither “economic seclusion” nor “mendicancy.”