3/18/26, 10:17 AM

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The Supreme Court (SC) has dismissed a petition questioning the validity of a Manila City ordinance that updated the city’s garbage collection fees.

In a resolution, the SC En Banc ruled that the petition filed by John Barry T. Tayam against Manila City Mayor Francisco M. Domagoso and the City Council failed to meet the basic requirements of judicial review.

The assailed measure, Ordinance No. 9151, was enacted by the Manila City Council in November 2025. It introduced a revised schedule of garbage collection fees—the first update since 2013.

Tayam, a resident of Las Piñas City, argued that the ordinance was invalid because it was approved without publication, allegedly violating Article 2 of the Civil Code and Section 187 of the Local Government Code (LGC). He also claimed the increased fees exceeded the cost of waste regulation, in violation of the LGC, and that the ordinance ran contrary to Republic Act No. 9003, or the Ecological Solid Waste Management Act, by disregarding the role of barangays and policies promoting waste reuse and recycling.

The SC, however, rejected these arguments, ruling that Tayam had no legal standing to file the petition. It explained that a petitioner must show a personal and substantial interest in the case and demonstrate that they would be directly affected by the government action being challenged.

The Court noted that the ordinance applies only to businesses, service agencies, and residents within Manila. Tayam neither resides nor operates a business in the city, placing him outside the scope of those directly affected.

The SC also ruled that the case could not be treated as a taxpayer’s suit—an exception to the rule on legal standing. It stressed that such suits are allowed only when there is an alleged illegal disbursement of public funds or an unconstitutional tax measure. In this case, the ordinance was deemed a regulatory measure, not a tax or revenue measure.

The Court further rejected Tayam’s claim that the case involved issues of “transcendental importance” that would justify relaxing the rules on standing. It said the petition raised factual questions—such as whether the ordinance was properly published, whether public hearings were conducted, and whether the fees exceeded regulatory costs—which require the presentation of evidence.

As the SC is not a trier of facts, it cannot resolve such matters, the ruling said.

Finally, the Court held that the petition violated the doctrine of the hierarchy of courts, as it was filed directly with the SC. It emphasized that such factual issues must first be brought before the appropriate regional trial court, which has the authority to receive and evaluate evidence.