In 2010, the Philippine Supreme Court led the Philippines to become the first nation with rules of procedure specific to environmental cases. While the Philippines has made great strides in adopting environmental laws and providing access to courts, more work is needed to ensure consistent decisions and to build capacity in both lower courts and government agencies. As shown in the case of Metropolitan Manila Development Authority v. Concerned Residents of Manila Bay, the Court will need to find a balance between making environmental laws a reality and taking on more than it can (and should) handle.