G.R. No. 214752 - Equitable Savings Bank vs. Palces

On November 23, 2009, a brutal massacre occurred in Maguindanao, resulting in the killing of 57 individuals, including journalists.
In response, President Gloria Macapagal-Arroyo issued Proclamation No. 1946 on November 24, 2009, placing the Provinces of Maguindanao and Sultan Kudarat and the City of Cotabato under a state of emergency.
The President directed the Armed Forces of the Philippines (AFP) and Philippine National Police (PNP) to take measures allowed by law and the Constitution to prevent and suppress lawless violence in these areas.

On November 27, 2009, the President issued Administrative Order No. 273 (AO 273), purportedly "transferring" supervision of the Autonomous Region in Muslim Mindanao (ARMM) from the Office of the President to the Department of Interior and Local Government (DILG).
Due to disputes over the terminology used, AO 273 was amended by Administrative Order No. 273-A (AO 273-A), which "delegated" instead of "transferred" supervision of ARMM to the DILG Secretary.

Petitioners Datu Zaldy Uy Ampatuan (Governor), Ansaruddin Adiong (Vice-Governor), and Regie Sahali-Generale (Speaker of ARMM Regional Assembly), all officials of ARMM, challenged the constitutionality of Proclamation 1946 and AOs 273 and 273-A via a petition for prohibition under Rule 65.
They argued that these issuances violated the principle of local autonomy enshrined in the Constitution (Section 16, Article X) and Republic Act No. 9054 (Expanded ARMM Organic Act), claiming these empowered the DILG Secretary to take over ARMM operations and powers, including suspending and replacing ARMM officials.
Petitioners further maintained that the President had no factual basis for declaring a state of emergency, particularly regarding Sultan Kudarat and Cotabato City where no significant violent incidents occurred. They contended that the deployment of troops and the alleged takeover were invalid uses of emergency powers.
They sought a declaration that Proclamation 1946 and AOs 273 and 273-A were unconstitutional and requested injunctions against respondents (DILG Secretary, AFP, PNP) from executing or enforcing these instruments.

The Office of the Solicitor General (OSG) contended the President's actions aimed to restore peace and order, not to deny ARMM its autonomy.
The President acted pursuant to her constitutional power as Commander-in-Chief under Section 18, Article VII of the Constitution, calling out AFP and PNP to prevent or suppress lawless violence.
The delegation of supervision over ARMM to the DILG Secretary was a necessary administrative step to facilitate investigation of the massacre and did not constitute a takeover or confer blanket authority to suspend or replace officials.
Proclamation 1946 and the administrative orders did not involve the exercise of emergency powers as defined under Section 23(2), Article VI of the Constitution, as they did not proclaim a national emergency nor invoked extraordinary powers authorized by Congress.
Although the declared state of emergency’s immediate circumstances had improved, the Court’s ruling was necessary because acts performed under the proclamations and orders may bear on pending administrative and criminal cases.

Whether Proclamation No. 1946 and Administrative Orders Nos. 273 and 273-A violated the constitutional and statutory principle of local autonomy under Section 16, Article X of the Constitution and Section 1, Article V of the Expanded ARMM Organic Act (Republic Act No. 9054).

Whether President Arroyo’s issuance of Proclamation No. 1946 constituted an invalid exercise of emergency powers in calling out AFP and PNP to prevent and suppress lawless violence in Maguindanao, Sultan Kudarat, and Cotabato City.

Whether the President had factual bases to justify the declaration of a state of emergency and the subsequent call-out of the armed forces.