MANUEL MAMBA V.

EDGAR LARA
G.R. No. 165109, December 14, 2009
Facts:
The Sangguniang Panlalawigan of Cagayan passed
several resolutions authorizing Gov. Edgar Lara to
negotiate sign and e!ecute contracts or agree"ents for
the issuance and flotation of #onds to fun the priority
pro$ects of the governor and for the construction and
develop"ent of a %ew Cagayan Town Center su#$ect to
the approval and ratification of #y the Sangguniang
Panlalawigan. Su#se&uently the planning design
construction and site develop"ent of the pro$ect was
awarded to 'sset (uilders Corporation.
Petitioners )anuel )a"#a *ay"und Guz"an and
Leonidaz Fausto a *epresentative of Cagayan and
"e"#ers of the Sangguniang Panlalawigan respectively
filed a petition for 'nnul"ent of Contracts entered into #y
Gov. Lara in connection with the %ew Cagayan Town
Center pro$ect.
The Court dis"issed the petition for lac+ of course of
action stating a"ong others that petitioners did not have
the locus standi to file the present case as they are not
parties to the &uestioned contract.
,ssue:
-hether or not petitioners have locus standi to file the
petition.
*uling:
The Supre"e Court ruled that petitioners have legal
standing to sue as ta!payers. ' ta!payer is allowed to sue
where there is a clai" that pu#lic funds are illegally
dis#ursed or that the pu#lic "oney is #eing deflected to
any i"proper purpose or that there is wastage of pu#lic
funds through the enforce"ent of an invalid or
unconstitutional law. .owever for a ta!payer/s suit to
prosper two re&uisites "ust #e "et: 012 pu#lic funds
derived fro" ta!ation are dis#ursed #y a political
su#division or instru"entality and in doing so a law is
violated or so"e irregularity is co""itted and 032 the
petitioner is directly affected #y the alleged act. '
ta!payer need not #e a party to the contract to challenge
its validity. 's long as ta!es are involved people have a
right to &uestion the contracts entered into #y the
govern"ent.
,n this case although the construction of the town
center would #e pri"arily sourced fro" the proceeds of
the #onds a govern"ent support would still #e spent for
paying the interest of the #onds. 's to the second
re&uisite the court has rela!ed the stringent 4direct in$ury
test5 wherein ordinary citizens and ta!payers were
allowed to sue even if they failed to show direct in$ury #y
invo+ing 4transcendental i"portance5 4para"ount pu#lic
interest5 or 4far6reaching i"plications.5