Tanada vs.

Angara (272 SCRA 18)

[G.R. No. 118295. May 2, 1997]
Doctrine: Treaties and Agreement
Facts:
On April 15, 1994, the Philippine Government represented by its Secretary of the Department of
Trade and Industry signed the Final Act binding the Philippine Government to submit to its
respective competent authorities the WTO (World Trade Organization) Agreements to seek
approval for such. On December 14, 1994, Resolution No. 97 was adopted by the Philippine
Senate to ratify the WTO Agreement.
This is a petition assailing the constitutionality of the WTO agreement as it violates Sec 19,
Article II, providing for the development of a self reliant and independent national economy, and
Sections 10 and 12, Article XII, providing for the “Filipino first” policy.

Issue:
Whether or not the Resolution No. 97 ratifying the WTO Agreement is unconstitutional

Ruling:
The Supreme Court ruled the Resolution No. 97 is not unconstitutional. While the constitution
mandates a bias in favor of Filipino goods, services, labor and enterprises, at the same time, it
recognizes the need for business exchange with the rest of the world on the bases of equality
and reciprocity and limits protection of Filipino interests only against foreign competition and
trade practices that are unfair. In other words, the Constitution did not intend to pursue an
isolationalist policy. Furthermore, the constitutional policy of a “self-reliant and independent
national economy” does not necessarily rule out the entry of foreign investments, goods and
services. It contemplates neither “economic seclusion” nor “mendicancy in the international
community.”
The Senate, after deliberation and voting, gave its consent to the WTO Agreement thereby
making it “a part of the law of the land”. The Supreme Court gave due respect to an equal
department in government. It presumes its actions as regular and done in good faith unless
there is convincing proof and persuasive agreements to the contrary. As a result, the ratification
of the WTO Agreement limits or restricts the absoluteness of sovereignty. A treaty engagement
is not a mere obligation but creates a legally binding obligation on the parties. A state which has
contracted valid international obligations is bound to make its legislations such modifications as
may be necessary to ensure the fulfillment of the obligations undertaken.