I. Executive Summary: The Nexus of Extraction, Ecology, and Disaster

The catastrophic flooding witnessed across Cebu Province following Typhoon Tino (international name: Kalmaegi) in November 2025 1 was an acute disaster rooted in systemic environmental governance failures rather than purely meteorological forces. Analysis confirms that the unprecedented severity of the flood, which led to a province-wide state of calamity 2, was fundamentally amplified by decades of environmental degradation, specifically extensive, inadequately regulated large-scale quarrying and associated deforestation in the upland areas of the island.3

Cebu’s sensitive karst geology, which naturally manages water through rapid infiltration, was structurally degraded by extractive activities. This transformation converted the island's natural resilience mechanisms into mechanisms that accelerated runoff and flood severity.4 The regulatory system failed due to several interconnected factors: (1) a failure to accurately assess and enforce environmental carrying capacity limits in high-risk zones; (2) a critical gap in compliance among Local Government Units (LGUs) regarding climate risk integration mandated by the Department of the Interior and Local Government (DILG) Memorandum Circular 2022-018 6; and (3) a lack of predictable accountability for regulatory misfeasance or nonfeasance in the permitting process.7

Addressing this nexus requires a radical shift toward predictive, value-based resource governance. Key recommendations center on institutionalizing the Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act 8 to quantify the monetary cost of ecological damage, thereby strengthening the enforcement of carrying capacity, and leveraging a localized framework of the Philippine Extractive Industries Transparency Initiative (PH-EITI) to guide subnational disaster risk reduction and management (DRRM) funding, ensuring resources reach vulnerable, climate-exposed communities.

II. The Tino Disaster in Cebu: Context and Initial Impact Assessment

A. Meteorological and Hydrological Dimensions of Typhoon Tino

Typhoon Tino struck the central Philippines on November 4, 2025, bringing strong winds and torrential rains, causing devastating floods.1 The impact was widespread and severe; the entire province of Cebu was placed under a state of calamity.2 The subsequent Super Typhoon Uwan, following just four days later, intensified the crisis.1

The resulting hydrological event was characterized by unprecedented water levels. Floodwaters in affected communities ranged from waist-deep to reaching first-floor ceilings.9 Damage was extensive; in the Liloan, Compostela, Cebu City, Talisay City, and Balamban communities, homes were submerged, and vehicles were observed floating along streets overtaken by high water. This widespread destruction forced many families, including 98,260 families or 375,960 persons (DSWD DROMIC Report #21), into displacement, in local evacuation centers, or relatives, with significant impacts on household income and livelihood.9

B. Initial Linkages Identified: Unregulated Quarrying as a Non-Climate Driver

The severity of the flooding was quickly assessed by local authorities and civil society as exceeding typical typhoon impacts. Cebu Governor Pamela Baricuatro stated that the province was suffering its worst flooding in recent memory.3 Critically, the subsequent public and political discourse immediately linked the disaster to anthropogenic factors. A farmers' group emphasized that these impacts were "not entirely caused by natural disasters but by decades of environmental degradation".3

This conclusion was echoed by the Cebu City Council, which noted that "unabated" quarrying in upland barangays was a direct cause of the downstream flooding in major urban and coastal areas such as Metro Cebu, Cordova, Danao City, and Talisay City.3 The primary extractive activities involve the large-scale quarrying of materials like limestone and dolomite, utilized in cement production and other industries, and undertaken by major companies including Apo Cement, Taiheiyo Cement, Republic Cement, and others.3 The critical recognition that resource governance failures actively contributed to the catastrophe, converting a severe weather event into an unmitigated humanitarian crisis, underscores the failure of existing environmental safeguards to protect core resilience mechanisms.

III. Cebu's Environmental Sensitivity: Karst Geology and Hydrological Degradation

A. The Fragile Karst System of Cebu

Cebu Island possesses a unique and delicate geological foundation. Geologic maps from the Mines and Geosciences Bureau (MGB) indicate that at least 60% of the island is underlain by highly soluble limestones, resulting in a characteristic karst topography marked by conical hills, cave systems, and sinkholes.5

This karst system naturally functions as the island's primary hydrological regulator. It facilitates water infiltration and rapid subterranean drainage through its cavity and fracture networks, effectively managing high rainfall volumes.5 However, this system is inherently fragile. Sinkholes, which are semi-circular ground depressions formed over underground cavities, are vulnerable to collapse, which can be triggered by factors including intense flooding, changes in the water table, or destabilization from ground shaking.5

B. The Destructive Mechanism: Quarrying and Hydrological Degradation

Large-scale quarrying, particularly surface mining methods, disrupts the inherent resilience of the karst system. The process of extraction involves intensive mechanical excavation and blasting. Blasting beneath the quarry floor introduces high fracture density into the rock, which may be considered a "separate aquifer" with negligible natural porosity but artificially high fracture-induced conduit development.4

This practice fundamentally alters the natural hydrological function of the karst. Blasting-induced fracturing or aperture widening plays a role in initiating or accelerating flooding events.4 Instead of allowing for slow, natural infiltration and storage through the karst's original matrix, the damaged rock mass rapidly channels water. This disruption bypasses the slower, more controlled drainage processes, dramatically increasing the velocity and volume of surface runoff, thereby exacerbating the flash floods witnessed during Typhoon Tino. The island's natural sponge mechanism is structurally compromised, transforming the sensitive landscape into an efficient, rapid-delivery flood chute.

The tragic 2018 Naga City landslide, which resulted in 78 fatalities and was directly linked to dolomite quarrying 3, stands as a grim reminder of the intrinsic instability of these operations in Cebu’s geologically sensitive terrain.

C. Forest Cover Loss and Erosion Risk

The degradation of the karst system is compounded by severe forest cover loss. While data from 2020 show Cebu Province retained 139 kha of natural forest (29% of land area) 11, major downstream flood recipients like Cebu City only retained 18% natural forest cover.12 Between 2001 and 2024, Cebu City lost 615 ha of relative tree cover, equivalent to a 4.5% decrease since 2000.13

The removal of this protective vegetation cover, often linked to quarrying and large-scale earth-moving activities 14, significantly reduces water interception and absorption, leading to massive surface runoff and increased erosion. This runoff carries high sediment loads which choke downstream rivers and drainage canals, further magnifying the extent and duration of the flooding experienced during the Typhoon Tino event.3 This continuous, structural degradation illustrates a fundamental environmental injustice: localized extractive profits derived from upland areas create pervasive, widespread climate hazard risk borne disproportionately by distant, vulnerable downstream communities.

IV. Extractive Footprint and Regulatory Oversight in Cebu

A. The Scale of Extraction and Land Footprint

The density and scale of extractive activities in Cebu relative to the island's finite land mass present a profound contradiction in resource governance. Legal complaints filed previously in the wake of the Naga landslide alleged that 36 approved and subsisting Mineral Production Sharing Agreements (MPSAs) covered approximately 25,000 hectares, representing roughly 25% of Cebu Province’s total terrestrial domain of just over 500,000 hectares.15 This concentration of high-impact activities in a densely populated, climate-vulnerable archipelagic island signals a fundamental regulatory indifference to the concept of environmental carrying capacity.

Individual projects contribute significantly to this cumulative footprint. For instance, the Quarry Ventures Philippines, Inc. (QVPI) Cebu Marble and Aggregates Quarry Project covers a total MPSA area of 607.50 hectares across multiple parcels.16

B. Failures in Enforcement and Monitoring

The presence of widespread quarrying, despite numerous regulatory attempts to halt operations, demonstrates critical failures in enforcement and monitoring. In July 2025, the Cebu provincial government temporarily suspended all quarry operations province-wide for review.3 The Provincial Environment and Natural Resources Office (PENRO) subsequently ordered 19 companies holding quarry and special disposal permits to explain why their licenses should not be permanently revoked.17

Investigations uncovered multiple alleged violations, including permit holders operating outside of their officially designated areas and a pervasive lack of clear, visible boundary markers.17 The failure to clearly demarcate operational boundaries reflects both poor operator practice and inadequate regulatory monitoring.

Furthermore, even in areas under specific LGU bans, illegal operations persist. Following deadly landslides, Cebu City Mayor Michael Rama issued Executive Order 13 in 2022, indefinitely suspending quarrying and earth-moving in highly susceptible upland barangays.18 Yet, inspections as recent as July 2025 in Barangay Binaliw confirmed large-scale earth-moving by private firms without necessary permits, with thousands of truckloads of soil being hauled away.14 This demonstrates that the entire regulatory apparatus—from permit issuance to monitoring and enforcement—is compromised, leading to systemic environmental degradation whether activities are legal but non-compliant, or outright illegal. 

Table 2: Cebu's Environmental Risk Profile vs. Regulatory Mitigation Tools

V. Systemic Policy Deficiencies in Environmental Permitting

A. The Overlooked Mandate of Environmental Carrying Capacity

Remember that prior to this, two deadly slides happened in Cebu. One in 2018, in Naga City, and the other in 2020, in Toledo City, both within the earth-moving sections of the mines.

The Philippine Environmental Impact Statement System (PEISS), established under Presidential Decree 1586, institutionalized the Environmental Impact Assessment (EIA) as a crucial tool for reconciling development with environmental quality.20 A core requirement of this process for Environmentally Critical Projects (ECPs), such as large-scale mining and quarrying, is the assessment of the carrying capacity of the project area to absorb impacts.20 The objectives of the EIA scoping process explicitly include addressing issues related to the carrying or assimilative capacity of the environment.24

The evidence from Cebu suggests that this mandate has been consistently and systematically disregarded or improperly implemented. The simultaneous approval of permits covering a quarter of the island's sensitive karst terrain 15 while facing recurring, catastrophic climate-amplified disasters (such as Tino) demonstrates that the cumulative stress placed on the island’s finite hydrological systems exceeds any reasonable environmental limit. The persistent regulatory failures concerning carrying capacity mean that the EIA/ECC process functions as little more than a procedural compliance exercise, failing to act as a genuine preventative planning tool capable of constraining harmful activity.

B. Failures in Social Acceptability and Informed Public Participation

The EIA process also requires social acceptability, defined as an open, transparent process based on informed public participation involving the broadest range of stakeholders.22 This is intended to mitigate conflict and ensure cooperation.26

However, analyses of extractive sector governance indicate significant gaps between the policy's intent and actual practice.21 These gaps include proponents providing misleading statements and a lack of independent verification in EIAs.21 The resulting environmental degradation experienced by communities, including recurrent flash floods, crop destruction, and violence against protestors 27, proves that the mechanism for public participation often fails to translate into genuine community agency or veto power. Regulatory fragmentation, where the EIA process does not adequately coordinate with other environmental protection and development control programs, further contributes to this systemic failure.23

VI. LGU Compliance and Climate Risk Mainstreaming

A. Mandate Review: DILG Memorandum Circular 2022-018

The Department of Interior and Local Government (DILG) issued Memorandum Circular (MC) 2022-018 in February 2022 to strengthen LGU compliance concerning environmentally critical projects.6 The MC emphasizes the LGUs' duty to ensure that ECPs and projects located within Environmentally Critical Areas (ECAs) are consistent with their local development and sector plans.6

These plans include the Comprehensive Land Use Plan (CLUP), the Comprehensive Development Plan (CDP), and the Local Climate Change Action Plan (LCCAP), which must be developed based on rigorous Climate and Disaster Risk Assessment (CDRA).28 The intent of DILG MC 2022-018 is clear: an LGU may not approve a project that is inconsistent with its risk-sensitive plans. If a project is deemed acceptable but inconsistent, the LGU is required to update its plans and ordinances, or if a resolution for variance is issued, it must still conform to the CLUP and regional/provincial frameworks.6

B. Consistency Assessment and Enforcement Gaps

The continuing, widespread presence of quarrying in Cebu’s geohazard-susceptible upland barangays 18 strongly suggests that the consistency mandate is not being adequately enforced. This represents a critical failure point in decentralized environmental governance. There are two primary possibilities: either LGUs' CLUPs and LCCAPs are insufficiently robust in identifying and zoning high-risk areas, or the process of granting variances and issuing local endorsements is structurally utilized to circumvent the scientific findings of climate risk assessment, prioritizing extractive interests or local revenue goals over mandated resilience safeguards.

The latter scenario exposes a structural disconnect: national economic imperatives, often reflected in the power of national agencies like the MGB to issue MPSAs, effectively negate the LCCAP's intended function as a local land-use veto. Furthermore, the capacity gap is significant; as of 2022, only 41% of LGUs nationwide had submitted their LCCAPs.30 This lack of foundational planning documents means many LGUs in Cebu may be ill-equipped to conduct the rigorous consistency review required by DILG MC 2022-018, leading to uninformed or arbitrary permit decisions that systematically erode local resilience.

VII. Accountability, Predictability, and the Sibonga Case Study

A. Defining Nuanced Accountability in Regulatory Decisions

Environmental catastrophe necessitates an examination of regulatory actions through the lens of nuanced accountability, moving beyond simple corruption to diagnose failures in duty execution. Permit decisions must be predictable and transparent.31 Failures can be categorized across a spectrum of regulatory misconduct:

1. Nonfeasance (Failure to Act): This involves a failure to perform a duty when action is required.7 Examples include MGB or PENRO failing to conduct mandatory compliance monitoring, or LGUs neglecting to enforce suspension orders, thereby allowing continued illegal large-scale earth-moving operations, such as those observed in Binaliw.7

2. Misfeasance (Improper Execution): This involves performing a duty incorrectly or improperly, usually without intent to harm.7 This is arguably the most common failure in extractive permitting, occurring when regulatory bodies approve ECCs or MPSAs based on technically flawed or incomplete carrying capacity assessments, or grant land-use variances without rigorous consistency checks against the LCCAP.7

3. Malfeasance (Illegal Action): This refers to willful and intentional action designed to violate the law or cause harm.33 This requires intent, such as officials knowingly disregarding explicit regulations to benefit a proponent.

B. Case Analysis: The Cancelled MPSA in Sibonga, Cebu

The history of resource governance in Cebu is marked by reactive accountability rather than predictive prevention. The case of the MPSA in Sibonga, Cebu, covering 607.50 hectares for limestone and cement materials, provides a salient example.34 This MPSA, approved in 1999, was eventually cancelled by a DENR Order in July 2015, with the cancellation declared final and executory in April 2016.34    

But the cancellation of this MPSA has not stopped a similar proposal, in 2007, an ECC was granted to the same proponents, this time in another location within the Municiplaity. Having met with the same opposition, the application for MPSA had been stalled. In 2022, in a sporadic barangay meeting, it was later found out that the ECC had been reinstated. In 2023, in a similar event in another barangay, it was learned that the application was amended from an MPSA to an EP. These events demonstrate a profound failure of predictive governance. This time lag in accountability is a structural feature of the regulatory environment: damage is often irreversible or cumulative before consequences are enforced. The ultimate result for such misfeasance or nonfeasance is that continuous, inadequately regulated quarrying—whether legal or illegal—contributes directly to the erosion of natural capital, amplifying the physical drivers of disasters like Typhoon Tino.

VIII. Leveraging New Tools for Natural Capital Management

The failures in regulatory assessment and enforcement necessitate the institutionalization of tools that quantify environmental risk and damage in economic terms, thereby providing irrefutable, data-driven thresholds for decision-making.

A. The Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act

The Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act (RA 11995) represents a transformative legislative step, integrating ecosystem and natural capital considerations into economic and policy frameworks.8 Aligning with the UN System of Environmental-Economic Accounting (SEEA), PENCAS mandates the systematic measurement and valuation of natural assets.36

PENCAS achieves this by providing comprehensive statistics to monitor the depletion, degradation, and restoration of natural capital; assessing pollution levels; and calculating adjusted net savings.8 Crucially, PENCAS mandates the valuation of ecosystem services, such as water regulation and carbon sequestration—precisely the services provided by Cebu’s karst systems and forest cover that were lost to quarrying.36

B. Integrating PENCAS Metrics into LGU Planning and Environmental Risk Assessment

PENCAS offers a powerful mechanism to shift governance from reactive management to proactive risk mitigation. By putting nature on the national and local balance sheets, it enables LGUs to make holistic, evidence-based policy decisions that balance economic growth with ecological sustainability.36

The relevance to the Cebu flooding is paramount: PENCAS can quantify the full economic cost of losing the karst system's integrity—including the monetized value of increased DRRM expenditure, lost income, and property damage resulting from Typhoon Tino.10 If this quantifiable economic cost significantly outweighs the annual tax revenues generated by upland quarrying, PENCAS provides the financial justification for LGUs to proactively deny new permits or enforce existing carrying capacity limits. This converts the abstract concept of "environmental degradation" into quantifiable financial liabilities, shifting the debate from conservation ethics to fiscal prudence.

PENCAS data must be formally incorporated into the EIA process to establish an objective, monetized threshold for carrying capacity assessment, ensuring that decisions reflect the actual long-term trade-offs and risks involved.38 

Table 3: Integrating PENCAS Data into Climate-Extractive Governance 

IX. Strategic Recommendations for Archipelagic Solidarity and Subnational Transparency

A. Fostering Archipelagic Solidarity in Sustainable Development

As an archipelagic nation, the Philippines must coordinate resource management across island boundaries, fostering "archipelagic solidarity".39 In Cebu, this means transcending municipal borders to treat the island's sensitive karst watershed and its associated flood risks as a single, shared ecological unit.

A crucial structural reform is the institutionalization of a provincial-level "Karst Watershed Management Council." This body, composed of both upland LGUs (where quarrying occurs) and downstream urban centers (where flood impacts are felt 3), would be mandated to collaboratively review ECP/ECA permits. This mechanism ensures consistent land-use zoning and verifies that upland extractive impacts are mitigated across the entire watershed. Furthermore, LGUs must be supported in implementing Voluntary Local Reviews (VLRs) to comprehensively assess their progress, particularly toward SDG 15 (Life on Land), focusing on the restoration of forest cover and reduction of high-risk extractive land allocation.40 The lessons from Cebu's amplified disaster provide a critical, high-fidelity case study for other similarly geologically sensitive islands.

B. Enhancing PH-EITI Relevance for Local Resilience and DRRM

The Philippine Extractive Industries Transparency Initiative (PH-EITI) must evolve beyond purely financial revenue reconciliation to become a key governance tool for climate action, decentralization, and just transition.41

1. Data Disaggregation and Climate-Aligned Reporting

PH-EITI's subnational frameworks must be institutionalized.41 This requires moving beyond aggregate national data to publish highly granular, subnational data on company payments, specifically tracking environmental and social funds (e.g., Environmental Monitoring Fund, Social Development and Management Program contributions).41 Furthermore, PH-EITI must integrate climate-aligned reporting, including greenhouse gas (GHG) emissions (as emphasized in the "Carbon Clarity" initiative).44 This data provides the necessary foundation for policymakers to align extractive sector governance with regional climate risk exposure (CDRA).

2. Guiding Extractive Payments towards DRRM

The reconciled data from PH-EITI should not merely track company payments but ensure these funds are transparently and effectively directed towards specific, validated local DRRM needs. These needs include critical activities like slope stabilization, reforestation, and the construction of flood control infrastructure in municipalities affected by extractive operations.41

3. Highlighting Communities Left Behind

PH-EITI’s multi-stakeholder group platform must serve as an early warning mechanism for governance failures by actively highlighting local grievances.45 The inclusion of reports on negative impacts, such as flash floods, crop destruction, and violence against protestors caused by mining activities 27, is vital. By mapping the financial mitigation efforts of companies (tracked via EITI) against the PENCAS-quantified environmental damage (e.g., from Tino), the platform can expose disproportionality and ensure that affected communities are not left behind in the pursuit of economic development.

X. Conclusion: Towards Climate-Aligned Resource Governance

The severe flooding in Cebu caused by Typhoon Tino in 2025 serves as a definitive case study demonstrating the dangerous culmination of inadequate resource governance and escalating climate risk. The causal link is clear: the cumulative, structural degradation of Cebu's natural karst hydrogeology through large-scale, improperly regulated quarrying converted a meteorological threat into a major humanitarian and economic disaster.

Addressing this requires a decisive shift from reactive policing of environmental violations to predictive governance based on scientific limits. This includes the mandatory, rigorous application of environmental carrying capacity in permitting decisions. The mandate under DILG MC 2022-018 to ensure project consistency with risk-sensitive LGU plans (CLUP/LCCAP) must be enforced to prevent national economic policies from overriding local climate safeguards.

Ultimately, the future resilience of Cebu depends on data-driven accountability. The institutionalization of the PENCAS framework will provide the fiscal metrics necessary to expose regulatory misfeasance and justify conservation based on tangible economic costs. Concurrently, operationalizing a localized PH-EITI framework will ensure transparency in resource revenues and, crucially, verify that environmental and social payments are effectively utilized to build the climate resilience necessary for archipelagic stability.

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