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	GR NO. 167324 2007-07-17	TONDO MEDICAL CENTER EMPLOYEES ASSOCIATION v. CA CHICO-NAZARIO, J.
In a number of cases,[41] the Court upheld the standing of citizens who filed suits, wherein the "transcendental importance" of the constitutional question justified the granting of relief. In spite of these rulings, the Court, in Domingo v. Carague,[42] dismissed the petition when petitioners therein failed to show any present substantial interest. It demonstrated how even in the cases in which the Court declared that the matter of the case was of transcendental importance, the petitioners must be able to assert substantial interest. Present substantial interest, which will enable a party to question the validity of the law, requires that a party sustained or will sustain direct injury as a result of its enforcement.[43] It is distinguished from a mere expectancy or future, contingent, subordinate, or inconsequential interest.[44]
	GR NO. 169777 2006-04-20	SENATE OF PHILIPPINES v. EDUARDO R. ERMITA CARPIO MORALES, J.
Invoking this Court's ruling in National Economic Protectionism Association v. Ongpin[42] and Valmonte v. Philippine Charity Sweepstakes Office,[43] respondents assert that to be considered a proper party, one must have a personal and substantial interest in the case, such that he has sustained or will sustain direct injury due to the enforcement of E.O. 464.[44]