CONSTITUTION 1 CASE DIGESTS

JOHN DOMINIC MASACOTE JD-1D

LAGMAN et. al. VS MEDIALDEA G.R. No. 231658, G.R. No. 231771, G.R. No. 231774 July 4, 2017

Facts:

President Rodrigo Duterte issued Proclamation No. 216 on May 23, 2017, imposing martial law throughout
the whole island of Mindanao and suspending the right to writ of habeas corpus. According to the Philippine
Constitution, President Duterte was expected to provide a formal report to Congress on May 25 stating the
reasons why martial law was declared.

The Maute terrorist group's assault on Marawi City served as the main rationale for this statement.
According to the President's assessment, the Maute organization was associated with ISIS and sought to
create an Islamic rule in Marawi City with the potential to extend its rule throughout Mindanao. The study
also mentioned the persistent unrest and irrational violence that had plagued Mindanao for years.

Numerous petitions contested the legitimacy of Proclamation No. 216.

LAGMAN PETITION

According to the first petition, the Lagman group, martial law had no legitimate justification because there
was no uprising or invasion in Mindanao. It calls into doubt the government's claim that ISIS poses a threat
and characterizes it as propaganda.

CULLAMAT PETITION

The second petition, filed by Cullamat, challenges the legitimacy of martial law on the grounds that the
uprising was limited to Marawi City and did not warrant its implementation throughout all of Mindanao.

MOHAMAD PETITION

In the third petition, the group of Mohamad contends that martial law should only be used as a last resort
and that the circumstances in Marawi did not call for such drastic measures. The text emphasizes a number
of assertions and denials regarding whether the evidence supporting martial law is sufficient. The
government, represented by the Office of the Solicitor General, emphasizes that the burden of proof rests
with the petitioners and requests that the Court consider the question of sufficiency in light of the viewpoint
and knowledge that the President had at the time of the proclamation, as opposed to evaluating facts that
came to light later. President Duterte presented a report to Congress on May 25, 2017, outlining the
government's view of the situation in Mindanao, in an effort to defend the declaration. The Maute terrorist
group's and other local rebel groups' operations were noted in the study as proof of a serious security
danger.

Issues:

1. Is the petition reviewable by the court under Section 18, Article VII of the Philippine Constitution?
2. Does the court have the power to independently review the sufficiency of the factual basis for the
proclamation of martial law or the suspension of the privilege of the writ of habeas corpus, irrespective of
any actions taken by Congress?
3. Does the power of judicial review involve the assessment of the President's graduated powers as
Commander-in-Chief, namely calling out powers, suspension of the privilege of the writ of habeas corpus,
and declaration of martial law?
4. Was there a sufficient factual basis for the proclamation of martial law or the suspension of the privilege
of the writ of habeas corpus?

Ruling:

1. Yes, According to Section 18 of Article VII of the Philippine Constitution, the court may review the petition.
A citizen, including the petitioners, may contest the legality of the proclamation of martial law and the
suspension of the right to the writ of habeas corpus. Being a taxpayer is not necessary.

2. Yes, Regardless of Congress's actions, the court has the authority to review whether the factual foundation
for the declaration of martial law or the suspension of the privilege of the writ of habeas corpus is sufficient.
The court's function is to act as an additional barrier against any potential abuse of the President's authority
in using them.
3. No, Judicial review does not have the authority to dictate which extraordinary power the President should
exercise in a particular circumstance. The President may choose which power to use at his or her discretion
without regard to the graduated order of powers.

4. Yes, The declaration of martial law and the suspension of the writ of habeas corpus privilege had a
sufficient factual foundation, in other words. Based on the knowledge and information at his disposal at the
time of the declaration, the court found that the President's factual bases were sufficient. The President's
report was the only source of information that the court considered; unreliable news reports were not taken
into account. The alleged inaccuracies in the report did not change the court's conclusion that there was
actual rebellion, which was more likely than not the case. The Supreme Court acknowledged that the
Constitution gives the President the power to impose martial law and suspend the writ of habeas corpus
when there is a real uprising or invasion, and when public safety requires it.

Therefore, petition is DISMISSED

LAGMAN et.al. Vs MEDIALDEA(1st Extension)
GR No. 231658 , December 5, 2017

Facts:
On July 4, 2017, the Court rendered its Decision finding sufficient factual bases for the issuance of
Proclamation No. 216 and declaring it as constitutional. Petitioners timely filed separate Motions for
Reconsideration. The Office of the Solicitor General (OSG) also filed its Comment. After a careful review of
the arguments raised by the parties, we find no reason to reverse our July 4, 2017 Decision. All three
Motions for Reconsideration question two aspects of the July 4, 2017 Decision, i.e., the sufficiency of the
factual bases of Proclamation No. 216 and the parameters used in determining the sufficiency of the factual
bases. Petitioners, however, failed to present any substantial argument to convince us to reconsider our July
4, 2017 Decision.

Issue:
W/N the motion for reconsideration by the petitioners has merit.

Ruling:
Petitioners, in essence, posit that the Court is required to determine the accuracy of the factual basis of the
President for the declaration of martial law and/or the suspension of the privilege of the writ of habeas
corpus. To recall, we held that "the parameters for determining the sufficiency of factual basis are as follows:
1) actual rebellion or invasion; 2) public safety requires it; the first two requirements must concur; and 3)
there is probable cause for the President to believe that there is actual rebellion or invasion."
In determining the sufficiency of the factual basis of the declaration and/or the suspension, the Court should
look into the full complement or totality of the factual basis, and not piecemeal or individually. Neither
should the Court expect absolute correctness of the facts stated in the proclamation and in the written
Report as the President could not be expected to verify the accuracy and veracity of all facts reported to him
due to the urgency of the situation. the Court's power to review is limited to the determination of whether
the President in declaring martial law and suspending the privilege of the writ of habeas corpus had
sufficient factual basis. Thus, our review would be limited to an examination on whether the President acted
within the bounds set by the Constitution, i.e., whether the facts in his possession prior to and at the time of
the declaration or suspension are sufficient for him to declare martial law or suspend the privilege of the
writ of habeas corpus.

WHEREFORE, petitioners' Motions for Reconsideration are hereby DENIED WITH FINALITY for mootness
and lack of merit. No further pleadings shall be entertained. Let entry of judgment be made inn immediately.
SO ORDERED.
LAGMAN et.al. Vs MEDIALDEA (2nd Extension)
G.R. No. 235935, February 6, 2018

Facts:
In this case, Edcel C. Lagman et al. (petitioners) and other members of the Philippine House of
Representatives have petitioned the court. Through a joint resolution of Congress, the petitioners, including
Senate President Aquilino Pimentel III, Speaker Pantaleon D. Alvarez, and other government
representatives, sought to stop the extension of Martial Law in the Mindanao, Philippines.

The President asked the Congress to extend the validity of Proclamation No. 216 on July 18, 2017.
Proclamation No. 216 was extended by Resolution of Both Houses No. 26 by the Congress on July 22, 2017,
during a Special Joint Session.

Then, on December 13, 2017, the Senate and the House of Representatives passed a resolution to extend
Proclamation No. 216, Series of 2017, which was issued to "Declare a State of Martial Law and Suspend the
Privilege of the Writ of Habeas Corpus in the Whole of Mindanao," for an additional year, from January 1 to
December 31, 2018.

The petitioners questioned whether the martial law extension complied with the standards set forth in the
1987 Philippine Constitution, raising concerns about the extension's constitutionality. They claimed that
there was insufficient justification for the extension of martial law and that the requirements for doing so
were not met.

Issues:
1. W/N the extension of Martial Law in Mindanao complied with the constitutional requirements.

2. W/N the criteria for extending Martial Law were adequately met.

3. W/N the petitioners' constitutional rights were violated by the extension of Martial Law.

Ruling:

1. The Supreme Court decided to support the extension of martial law in Mindanao in a ruling. The Court
stated that the extension was based on the data and reports provided to Congress, and that a majority of
both the Senate and the House of Representatives had voted in favor of the extension.

2. The Court reiterated its role in this case, stating that, as long as the constitutional requirements were met,
it could not supplant Congress's authority to extend Martial Law. It emphasized that its authority to review
is restricted to the President's initial declaration of Martial Law and does not extend to evaluating the
wisdom and merits of the extension itself.

3. The Court further declared that it was outside of its purview to decide whether declaring martial law was
the best course of action given the circumstances in Mindanao. These choices must be made by the political
branches of the government.

WHEREFORE, the petition is DISMISSED, and DECLARE CONSTITUTIONAL Resolution of Both Houses
No.6
LAGMAN et.al. Vs MEDIALDEA(3rd Extension) G.R. No. 243522
February 19, 2019

Facts:

On May 23, 2017, President Duterte signed Proclamation No. 216, which declared martial law throughout
the entirety of Mindanao and suspended the previlige of the writ of habeas corpus. The declaration was
justified by the President citing the Maute Group's armed uprising and the threat of uprising by other
terrorist organizations. The initial duration of this proclamation was 60 days.

First Extension: On July 22, 2017, Congress, specifically the House of Representatives and the Senate,
convened in a joint session and approved the President's request for a 60-day extension of Martial Law.
They cited continued rebellion and the need to restore public order as reasons for the extension.

Second Extension: On December 13, 2017, President Duterte requested another extension of Martial Law in
Mindanao, this time for a period of one year, until December 31, 2018. The President's request was again
granted by Congress.

Third Extension: On December 5, 2018, President Duterte requested a third extension of Martial Law in
Mindanao, this time for another year until December 31, 2019. He asserted that there was still a need to
suppress the ongoing rebellion in the region. This request was granted by Congress.

Representatives Edcel C. Lagman, et al. (petitioners) challenged the third extension of Martial Law in
Mindanao, Philippines. The extension was made by President Rodrigo Duterte, and the petitioners sought to
declare it unconstitutional and without sufficient factual basis.

Issues:

1. W/N the third extension of Martial Law in Mindanao complied with the constitutional requirements.

2. W/N there was sufficient factual basis for the third extension of Martial Law.

3. W/N the petitioners' constitutional rights were violated by the third extension of Martial Law.

Ruling:

The Supreme Court upheld the constitutionality of the third extension of martial law in Mindanao in a
majority decision. The extension was approved by a majority vote in both the Senate and the House of
Representatives, and the Court acknowledged that it was based on data and reports provided to Congress.

The Court reaffirmed that its authority to review is restricted to the President's initial proclamation of
martial law and does not include examining the propriety and merits of the extensions themselves. It
emphasized how critical it is to respect the political branches of government when they make decisions
about imposing martial law.

Regarding the sufficiency of the factual basis, the Court ruled that the President was not required to show
that there had been an actual uprising or invasion after the initial 60-day proclamation of martial law. The
information provided to Congress was deemed sufficient to support the extension, and the Court was not in
a position to call into question the veracity of the information on which the President and the legislators had
relied.

The third extension of martial law in Mindanao was upheld as CONSTITUTIONAL by the Supreme Court,
which emphasized that it adhered to all legal requirements. The Court's responsibility was reduced to
reviewing the initial declaration of Martial Law after the petitioners' challenge to the extension was rejected.
In addition to highlighting the separation of powers between the judiciary and the legislature in such
matters, this decision upheld the legality of the third extension of martial law in Mindanao.