KULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR.

ANGELINA GALANG, LEONARDO AVILA III, CATHERINE UNTA

N, MAYOR EDWARD S. HAGEDORN, and EDWIN MARTHINE LOPEZ, Respondents.

URCES, BUREAU OF PLANT INDUSTRY AND THE FERTILIZER AND PESTICIDE AUTHORITY OF THE DEPARTMENT OF AGRICULTURE, Petition

APAUNLAD NG AGRIKULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR. ANGELINA GALANG, LEONARDO AVILA
ADO, NOEL CABANGON, MAYOR EDWARD S. HAGEDORN, and EDWIN MARTHINE LOPEZ, Respondents.
KULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR. ANGELINA GALANG, LEONARDO AVILA III, CATHERINE UNTA
ON, MAYOR EDWARD S. HAGEDORN, and EDWIN MARTHINE LOPEZ, Respondents.

KULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR. ANGELINA GALANG, LEONARDO AVILA III, CATHERINE UNTA
ON, MAYOR EDWARD S. HAGEDORN, and EDWIN MARTHINE LOPEZ, Respondents.

f the Court (December 8, 2015 Decision), which upheld with modification the Decision3 dated May 17, 2013 and the Resolution4 dated Sep

ngiensis (Bt) eggplant (Bt talong), administered pursuant to the Memorandum of Undertaking5 (MOU) entered into by herein petitioners U
PMFI), among others. Bt talong contains the crystal toxin genes from the soil bacterium Bt, which produces the CrylAc protein that is toxic

f the field trials, conducted a contained experiment on Bt talong under the supervision of the National Committee on Biosafety of the Phil
oduction of new species and genetically engineered organisms and recommend measures to minimize risks"; and (b) ''formulate and revie
pervise the implementation thereof."9 Upon the completion of the contained experiment, the NCBP issued a Certificate10 therefor stating t

mits12 for field testing of Bt talong13after UPLB's field test proposal satisfactorily completed biosafety risk assessment for field testing pursu
f plants and plant products derived from the use of modern biotechnology.16 Consequently, field testing proceeded in approved trial sites

piko sa Pagpapaunlad ng Agrikultura (MASIPAG), and others (respondents) filed before the Court a Petition for Writ of Continuing Manda
EMB) of the Department of Environment and Natural Resources (DENR), the BPI and the Fertilizer and Pesticide Authority (FPA) of the DA,
e (ECC), as required by Presidential Decree No. (PD) 1151,19 was not secured prior to the field trials;20 (b) the required public consultations
dent, peer-reviewed study showing its safety for human consumption and the environment.22 Further, they contended that since the scien
y, the field trials be enjoined.23

ng them to make a verified return within a non-extendible period of ten (10) days, as provided for in Section 8, Rule 7 of the Rules of Proc
e complied with, including the required public consultations in the affected communities; (b) an ECC was not required for the field trials as
rate, the safety of Bt talong for human consumption is irrelevant because none of the eggplants will be consumed by humans or animals a
t of a continuing study to ensure that such trials have no significant and negative impact on the environment.29
f the return of the writ and for hearing, reception of evidence, and rendition of judgment.31 In a hearing before the CA on August 14, 2012
its Answer33 adopting the arguments and allegations in the verified return filed by UPLBFI. On the other hand, in a Resolution34 dated Febr

ently cease and desist from conducting the Bt talong field trials.36 At the outset, it did not find merit in petitioners' contention that the cas
rall and bigger study that is being conducted in relation to the said genetically-modified organism.37 It then held that the precautionary pri
e possible irreversible effects of the field trials and the introduction of Bt talong to the market, and found the existing regulations issued b

20, 2013, the CA denied the same and remarked that introducing genetically modified plant into the ecosystem is an ecologically imbalanc
ting the field trials, and only at this time when there is yet no law ensuring its safety when introduced to the environment.44

cation the ruling of the CA.46 Agreeing with the CA, the Court held that the precautionar; principle applies in this case since the risk of harm
scale farmers who are poor and marginalized; thus, given the country's rich biodiversity, the consequences of contamination and genetic

mpletion and termination of the Bt talong field trials, on account of the following exceptions to the mootness principle: (a) the exceptiona

amework (NBF) established under EO 514, series of 200649 which requires public participation in all stages of biosafety decision-making, pu
ected to Environmental Impact Assessment (EIA), considering that it involved new technologies with uncertain results.52

and void for failure to consider the provisions of the NBF. The Court also temporarily enjoined any application for contained use, field tes

een dismissed for mootness in view of the completion and termination of the Bt talong field trials and the expiration of the Biosafety Perm
not offered in evidence and involved Bt corn, not Bt talong.57

completion of the field trials since field testing is part of the process of commercialization and will eventually lead to propagation, comme
nce is not enough to adequately protect the Constitutional right of the people to a balanced and healthful ecology;60 and (c) the Court cor

a "case" or an "actual controversy" for the proper exercise of the power of judicial review proceeds from Section 1, Article VIII of the 198

lished by law.

are legally demandable and enforceable, and to determine whether or not there has been a grave abuse of discretion amounting to lack or
rinciples or rules of law which cannot affect the result as to the thing in issue in the case before it. In other words, when a case is moot, it

ved have become academic or dead or when the matter in dispute has already been resolved and hence, one is not entitled to judicial inte

ion of the Constitution; second, the exceptional character of the situation and the paramount public interest are involved; third, when the
these four instances as exceptions to the mootness principle.

er and paramount public interest is involved, and (b) it is likewise capable of repetition yet evading review. Hence, it was excepted from th
and academic, and that the aforesaid exceptions to the said rule should not have been applied.

ount public interest in relation to the mootness principle. However, a survey of cases would show that, as a common guidepost for applica

Act No. (RA) 4880,68 which prohibits the early nomination of candidates for elective offices and early election campaigns or partisan politi
ramount public interest and the undeniable necessity for a ruling, the national elections [of 1969] being barely six months away."69

t case notwithstanding the supervening death of one of the contestants. According to the Court, in an election contest, there is a paramou

7, s. 2006,73 which declared a state of National Emergency, even though the same was lifted before a decision could be rendered. The Cou

er Section 3 (e) of RA 3019.76 One of the accused appealed the conviction, while the other filed a petition for certiorari before the Court. W
intertwined that the absolution of the deceased was determinative of the absolution of the other accused.77

mission on Audit (COA) be ordered to audit the MECO which is based in Taiwan, on the premise that it is a government-owned and control
rits, the Court explained that the case was of paramount public interest because it involved the COA's performance of its constitutional du
of the People's Republic of China.81

e gained by resolving respondents' petition for Writ of Kalikasan on the merits.

ed by the undisputed expiration of the Biosafety Permits issued by the BPI and the completion and termination of the Bt talong field trials
he time the CA rendered its Decision dated May 17, 2013, the reliefs petitioner sought and granted by the CA were no longer capable of ex

mean that herein petitioners may inevitably proceed to commercially propagate Bt talong.83 There are three (3) stages before genetically-m
e is given to engage in the next regulatory stage."85 Specifically, before a genetically modified organism is allowed to be propagated under
nvironment; (c) food and/or feed safety studies show that the regulated article will not pose any significant risks to human and animal hea

were pursued or the requirements therefor complied with. Thus, there are no guaranteed after-effects to the already concluded Bt talong
more imagined than real.

GMOs, for that matter - until an actual and justiciable case properly presents itself before the Court. In his Concurring Opinion87 on the ma
f the various claims made in relation to Bt talong."88 True enough, the concluded field tests ·- like those in these cases – would yield data t
MOs in general, and hence, tend to hinder scientific advancement on the subject matter.
als whose parameters are not only unique to the specific type of Bt talong tested, but are now, in fact, rendered obsolete by the superve
nt of Science and Technology (DOST), the DA, the DENR, the Department of Health (DOH), and the Department of Interior and Local Gove
tantamount to an unnecessary scholarly exercise for the Court to assess alleged violations of health and environmental rights that arose f

phi1

evading review" exception.

of Bt talong under the premises 'of DAO 08,..2002,91 i.e., that herein petitioners failed to: (a) fully inform the eople regarding the health, e
he use of the results of the field trials that have been completed. Hence, the petition's specificity prevented it from falling under the abov

capable of repetition so as to warrant review despite its mootness. To contextualize, JDC 01-2016 states that:

d use, transboundary movement, release into the environment, and management of genetically-modified plant and plant products derive

testing now applies.

act, the new parameters in JDC 01-2016 pertain to provisions which prompted the Court to invalidate D'AO 08-2002. In the December 8, 2
participation requirements under the NBF;96 and (c) risk assessment is conducted by an informal group, called the Biosafety Advisory Team

wed to consider the expert advice of, and guidelines developed by, relevant inteniational organizations and regulatory authorities of coun
g the research, development, handling and use, transboundary movement, release into the environment, and management of genetically
nts and plant products derived from the use of modern biotechnology,100 under JDC 01-2016, various relevant government agencies such a

rials and requires applications for permits and permits already issued to be made public by posting them online in the websites of the NCB
nity representatives.103 Previously, under DAO 08-2002, the only requirement for the community representatives is that they shall not be a

Panel (STRP), the pool of scientists that evaluates the risk assessment submitted by the applicant for field trial, commercial propagation, o
ployed or engaged by a company or institution with pending applications for pennits under JDC 01-2016; (b) must possess technical exper
tific community.105

-2016:

DAO 08-2002 JDC 01-2016

1. As to coverage and government participation

WHEREAS, under Title IV, Chapter 4, Section 19 ARTICLE I. GENERAL PROVISIONS

of the Administrative Code of 1987, the
Department of Agriculture, through the Bureau Section 1. Applicability. This Joint Department
of Plant Industry, is responsible for the Circular shall apply to the research,
production of improved planting materials and development, handling and use, transboundary
protection of agricultural crops from pests and movement, release into the environment, and
diseases; and management of genetically-modified plant and
plant products derived from the use of modern
xxxx biotechnology, included under "regulated
PART I articles."
GENERAL PROVISIONS xxxx
xxxx
ARTICLE III. ADMINISTRATIVE
PART I
FRAMEWORK
GENERAL PROVISIONS
Section 4. Role of National Government
xxxx Agencies Consistent with the NBF and the laws
Section 2 granting their powers and functions, national
Coverage government agencies shall have the following
roles:
A. Scope - This Order covers the importation or
release into the environment of: 1. Any plant A. [DA]. As the principal agency of the Philippine
which has been altered or produced through Government responsible for the promotion of
the use of modem biotechnology if the donor agricultural and rural growth and development
organism, host organism, or vector or vector so as to ensure food security and to contribute
agent belongs to any of the genera or taxa to poverty
classified by BPI as meeting the definition of alleviation, the DA shall take the lead in
plant pest or is a medium for the introduction addressing biosafety issues related to the
of noxious weeds; or country's agricultural productivity and food
2. Any plant or plant product altered or security.x x x.
produced through the use of modern B. [DOST]. As the premier science and
biotechnology which may pose significant risks technology body in the country, the DOST shall
to human health and the environment based on take the lead in ensuring that the best available
available scientific and technical information. science is utilized and applied in adopting
B. Exceptions. - This Order shall not apply to the biosafety policies, measures and guidelines, and
contained use of a regulated article, which is in making biosafety decision.
within the regulatory supervision of NCBP. x xx.

C. [DENR]. As the primary government agency

responsible for the conservation management,
development and proper use of the country's
 environment and natural resources, the DENR
shall ensure that environmental assessments
are done and impacts identified in biosafety
decisions. x x x.

D. [DOH]. The DOH, as the principal authority

on health, shall formulate guidelines in
assessing the health impacts posed by modern
biotechnology and its applications. x x x.

E. [DILG]. The DILG shall coordinate with the

DA, DOST, DENR and DOH in overseeing the
implementation of this Circular in relation to
the activities that are to be implemented in
specific LGUs, particulady in relation to the
conduct of public consultations as required
under the Local Government Code. x x x.

2. As to guidelines in risk assessment

PART I ARTICLE II. BIOSAFETY DECISIONS

GENERAL PROVISIONS Section 3. Guidelines in Making Biosafety

Decisions
xxxx
The principles under the NBF shall guide
Section 3 concerned agencies in making biosafety
Risk Assessment decisions, including:
A. Principles of Risk Assessment - No regulated xxxx
article shall be allowed to be imported or
released into the environment without the B. Risk Assessment. Risk assessment shall be
conduct of a risk assessment performed in mandatory and central in making biosafety
accordance with this Order. The following decisions, consistent with policies and
principles shall be followed when performing a standards on risk assessment issued by the
risk assessment to determine whether a NCBP; and guided by Annex III of the Cartagena
regulated article poses significant risks to Protocol on Biosafety. Pursuant to the NBF, the
human health and the environment: following principles shall be followed when
performing a risk assessment to determine
1. The risk assessment shall be carried out in a whether a regulated article poses significant
scientifically sound and transparent manner risks to human health and the environment.
based on available scientific and technical
information. The expert advice of, and 1. The risk assessment shall be carried out in a
guidelines developed by, relevant international scientifically sound and transparent manner
organizations and regulatory authorities of based on available scientific and technical
countries with significant experience in the information. The expert advice of and
regulatory supervision of the regulated article guidelines developed by, relevant international
shall be taken into account in the conduct of organizations, including intergovernmental
risk assessment. bodies, and regulatory authorities of countries
with significant experience in the regulatory
x x xx supervision of the regulated article shall be
taken into account. In the conduct of risk
assessment, CODEX Alimentarius Guidelines on
the Food Safety Assessment of Foods Derived
from the Recombinant-DNA Plants shall
internationally adopted as well as other
internationally accepted consensus documents.

x x x x (Underscoring supplied)

3. As to public participation

PART III ARTICLE V. FIELD TRIAL OF REGULATED

APPROVAL PROCESS FOR FIELD TESTING OF ARTICLES
REGULATE ARTICLES
Section 12. Public Participation for Field Trial
xxxx
A. The BPI shall make public all applications and
Section 8 Biosafety Permits for Field Trial through posting
on the NCBP and BPI websites, and in the
Requirements for Field Testing offices of the DA and DOST in the province, city,
xxxx or municipality where the field trial will be
conducted.
G. Public Consultation. - The applicant, acting
through its IBC, shall notity and invite x x xx
comments on the field testing proposal from
the barangays and city/municipal governments
with jurisdiction over the field test sites. The IBC
shall post for three (3) consecutive weeks
copies of the Public Information Sheet for Field
Testing approved by the BPI in at least three (3)
conspicuous places in each of the concerned
barangay and city/municipal halls. The Public
Information Sheet for Field Testing shall, among
others, invite interested parties to send their
comments on the proposed field testing to BPI
within a period of thirty (30) days from the date
of posting. It shall be m a language understood
in the community. During the comment period,
any interested person may submit to BPI
written comments regarding the application.
The applicant shall submit proof of posting in
the form of certifications from the concerned
barangay captains and city/municipal mayors or
an affidavit stating the dates and places of
posting duly executed by the responsible officer
or his duly authorized representative.

4. As to membership in the Institutional Biosafety Committee

PART I ARTICLE III. ADMINISTRATIVE

GENERAL PROVISIONS
FRAMEWORK
Section 1
xxxx
Definition of Terms
Section 6. Institutional Biosafety Committee
xxxx
The company or institution applying for and
L. "IBC" means the Institutional Biosafety granted permits under this Circular shall
Committee established by an applicant in constitute an IBC prior to the contained use,
preparation for the field testing of a regulated confined test, or field trial of a regulated article.
article and whose membership has been The membership of the IBC shall be approved
approved by BPI. The JBC shall be responsible by the DOST-BC for contained use or confined
for the initial evaluation of the risk assessment test, or by the DA-BC for field trial. The IBC is
and risk management strategies of the applicant responsible for the conduct of the risk
for field testing. It shall be composed of at least assessment and preparation of risk
five (5) members, three (3) of whom shall be management strategies of the applicant for
designated as "scientist-members" who shall contained use, confined test, or field trial. It
possess scientific and technological knowledge shall make sure that the environment and
and expertise sufficient to enable them to human health are safeguarded in the conduct of
evaluate and monitor properly any work of the any activity involving regulated articles.
applicant relating to the field testing of a
regulated article. The other members, who shall The IBC shall be composed of at least five (5)
members, three (3) of whom shall be
be designated as "community representatives",
shall not be affiliated with the applicant apart designated, as scientist-members and two (2)
from being members of its IBC and shall be in a members shall be community representatives.
position to represent the interests of the All scientist-members must possess scientific or
communities where the field testing is to be technological knowledge and expertise
conducted. For the avoidance of doubt, NCBP sufficient to enable them to property evaluate
shall be responsible for approving the and monitor any work involving regulated
membership of the IBC for contained use of a articles conducted by the applicant.
regulated article.
The community regresentative must not be
x x x x (Underscoring supplied) affiliated with the applicant, and must be in a
position to regresent the interests of the
communities where the activities are to be
conducted. One of the community
regresentatives shall be an elected official of
the LGU. The other community representative
shall be selected from the residents who are
members of the Civil Society Organizations
represented in the Local Poverty Reduction
Action Team, pursuant to DILG Memorandum
Circular No. 2015-45. For multi-location trials,
community representatives of the IBC shall be
designated per site. x x x. (Underscoring
supplied)

5. As to the composition and qualifications of the members of the Scientific and Technical
Review

Panel

PART I ARTICLE III. ADMINISTRATIVE FRAMEWORK

GENERAL PROVISIONS
xxxx
Section 1
Section 7. Scientific and Technical Review
Definition of Terms Panel (STRP) The DA shall create a Scientific and
Technical Review Panel composed of a pool of
xxxx non-DA scientists with expertise in the
EE. "STRP" means the Scientific and Technical evaluation of the potential risks of regulated
Review Panel created by BPI as an advisory articles to the environment and health. x x x
body, composed of at least three (3) reputable
xxxx
and independent scientists who shall not be
 employees of the Department and who have The DA shall select scientists/experts in the
the relevant professional background STRP, who shall meet the following
necessary to evaluate the potential risks of the qualifications:
proposed activity to human health and the
environment based on available scientific and A. Must not be an official, staff or employee of
technical information. the DA or any of its attached agencies;

B. Must not be directly or indirectly employed

x x x x (Underscoring supplied)
or engaged by a company or institution with
pending applications for permits covered by this
Circular;

C. Possess technical expertise in at least one of

the following fields: food and nutrition;
toxicology, ecology, crop protection,
environmental science, molecular biology and
biotechnology, genetics, plant breeding, animal
nutrition; and

D. Well-respected in the scientific community as

evidenced by positions held in science-based
organizations, awards and recognitions,
publications in local and international peer-
reviewed scientific journals.

x x x x (Underscoring supplied)

sment in matters involving the research, development, handling, movement, and release into the environment of genetically modified pla
ble of repetition yet evading review.

a v. Ochoa, Jr.,106 where the constitutionality of the Executive Department's lump-sum, discretionary funds under the 2013 General Appro
ms undertaken by the Executive Department and former President Benigno Simeon S. Aquino III's declaration that he had already "abolishe
, the Court ruled that it is one capable of repetition yet evading review, thus:

the preparation and passage of the national budget is, by constitutional imprimatur, an affair of annual occurrence. The relevance of th
nce of truth to petitioners' claim that "the same dog will just resurface wearing a different collar." In Sanlakas v. Executive Secretary, th
uation similarly holds true to these cases. Indeed, the myriad of issues underlying the manner in which certain public funds are spent, if no

To reiterate, the issues in these cases involve factual considerations which are peculiar only to the controversy at hand since the petition f

capable of repetition yet evading review: (1) the challenged action was in its duration too short to be fully litigated prior to its cessation or

It must be emphasized that the Biosafety Permits for the subject field tests were issued on March 16, 2010 and June 28, 2010, and were v
 the field testing activities were already over.108 Obviously, therefore, the cessation of the subject field tests before the case could be reso

08-2002 has already been superseded by JDC 01-2016. Hence, future applications for field testing will be governed by JDC 01-2016 which, a

f the absence of any valid exceptions to the rule on mootness, and to thereupon rule on the objections against the validity and consequen

nality of DAO 08-2002 as it was merely collaterally challenged by respondents, based on the constitutional precepts of the people's rights
2 before the Court shows that they essentially assail herein petitioners' failure to: (a) fully infom1 the people regarding the health, environ
stitutional right of the people to a balanced and healthful ecology since "said regulation failed, among others, to anticipate 'the public imp
environment, [and] thus, x x x fall short of Constitutional compliance,"113 respondents merely prayed for its amendment, as well as that o
ve implementation, in accord with international safety standards[.]"114 This attempt to assail the constitutionality of the public info1matio
erally attacked as constitutionality issues must be pleaded directly and not collaterally.115 Verily, the policy of the courts is to avoid ruling o
means that the measure had first been carefuliy studied by the executive department and found to be in accord with the Constitution befo

ermits and the completion of the field trials subject of these cases, and with none of the exceptions to the mootness principle properly att

ourt, which affirmed with modification the Decision dated May 17, 2013 and the Resolution dated September 20, 2013 of the Court of App
e of a Temporary Environmental Protection Order (TEPO) filed by respondents Greenpeace Southeast Asia (Philippines), Magsasaka at Siy

ANTONIO T. CARPIO* PRESBITERO J. VELASCO, JR.

Associate Justice Associate Justice

TERESITA J. LEONARDO-DE CASTRO ARTURO D. BRION

Associate Justice Associate Justice

DIOSDADO M. PERALTA LUCAS P. BERSAMIN

Associate Justice Associate Justice

MARIANO C. DEL CASTILLO JOSE PORTUGAL PEREZ

Associate Justice Associate Justice
 JOSE CATRAL MENDOZA BIENVENIDO L. REYES
Associate Justice Associate Justice

See Separate Concurring Opinion No Part

MARVIC M.V.F. LEONEN FRANCIS H. JARDELEZA**
Associate Justice Associate Justice

y that the conclusions in the above Resolution been reached in consultation before the case was assigned to the writer of the opinion of th

9276], Vol. IX, pp. 4681-4718); (2) E-Parte Manifestation with MR filed by ISAAA on January 7, 2016 (id. at 4746-4778); (3) MR filed by inter
on January 14, 2016 (id. at 4836-4863); (5) Urgent Motion to Intervene (with [MR]-in-Intervention) filed by Alyansa ng mga Grupong Hali
bruary 3, 2016 (id. at 4953-4980); (8) Petition/[MR]-inIntervention filed by Philippine Association of Feed Millers, Inc. on February 16, 201

stices Myra V, Garcia-Fernandez and Nina G. Antonio-Valenzueia concurring.

of Contained Experiment issued on the same date; CA rollo, Vol. II, pp. 885-886.

OTHER PORPOSES" (October 15, 1990).

ANTS AND PLANT PRODUCTS DERIVED FROM THE USE OF MODERN BIOTECHNOLOGY," adopted on April 3, 2002.

asan nor furnished with a copy of the petition filed by respondents. (See Resolution dated August 17, 2012 of the CA; CA rollo, Vol. III, pp. 2

ties who were served of the Writ of Kalikasan. Also, UPLB was unintentionally included as one of the parties who were served the same. S

Temporary Environmental Protection Order (TEPO) filed by ISAAA on May 21, 2012 (CA rollo, Vol. I, pp. 437-544); Return of the Writ filed b
I, pp. 2081-2090).

ol. II, pp. 2114-2116.

human activity and environmental effect, the court shall apply the precautionary principle in resolving the case before it. The constitution

88); ISAAA's MR datt:d June 11, 2013 {id. at 3893-3946); TJPLB's MR dated June 10, 2013 (id. at 3949-3958); and UPLBFI's MR dated June 1

EMENTATION, STRENGTHENING THE NATIONAL COMMITTEE ON BIOSAFETY OF THE PHILIPPINES, AND FOR 0THTIR PURPOSES," approved

Philippines on May 24, 2000 and entered into force on September 11, 2003.

76), Vol. IX, pp. 4681-4718); E-Parte Manifestation with MR filed by ISAAA on January 7, 2016 (id. at 4746-4778); MR filed by intervenor Bi
d by Alyansa ng niga Grupong Haligi ng Agham at Teknolohiya para sa Mamamayan (AGHAM) on February 2, 2016 (id.at 4903-4922); MR f
ed Millers, Inc. on February 16, 2016 (id. at 4998-5027). See also Manifestation filed by Edgar C. Talasan, et al. (Fanners) on January 20, 20

15.
for Reconsideration-in-Intervention of AGHAM Partylist dated April 12, 2016 (id. at 5054-5067) und Consolidated Comment and Oppositio
nd Consolidated Comment dated May 2, 2016 filed by intcrvenors Pambansang Kilusan ng mga Samahang Magsasaka (PAKISAMA), Sibdl

'THE REVISED ELECTION CODE', BY LIMITING THE PERIOD OF ELECTION CAMPAIGN, lNSERTING FOR THIS PURPOSE NEW SECTIONS THEREI
ical containment facility for purposes of laboratory experimentation; (2) Field Testing, where the regulated articles are intentionally inhud

130lJNDARY MOVEMENT, RELEASE INTO THE ENVIRONMENT, AND MANAGEMENT OF GE.N'ETICALLY-MODIFIED PLANT AND PLANT PROD
pouses Mirasol v. CA, 403 Phil. 760, 774 (2001).

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