Title
Source: Supreme Court
Esmero vs. Duterte
Case
G.R. No. 256288
Decision Date
Jun 29, 2021
Petitioner sought mandamus to compel President Duterte to defend West Philippine Sea; SC dismissed, citing presidential immunity, discretionary foreign policy powers, and mandamus inapplicability.

Case Digest (G.R. No. 256288)
Expanded Legal Reasoning Model

Facts:

  • Petition for Mandamus
    • Atty. Romeo M. Esmero (petitioner) filed a petition to compel President Rodrigo Roa Duterte to perform his constitutional duty to defend the national territory, including the West Philippine Sea, against alleged Chinese incursions.
    • Petitioner alleged that the President may consider engaging in a defensive war, call upon the people (and, by virtue of the Mutual Defense Treaty, the United States) to defend the State, and that his public pronouncements/actions are subject to judicial review.
  • Background and Alternative Proposals
    • In 2013, the Philippines under President Aquino invoked UNCLOS arbitration; in July 2016 the Arbitral Tribunal ruled overwhelmingly in favor of the Philippines.
    • Petitioner proposed that the Philippines invoke the UN Security Council’s “Uniting for Peace” Resolution, bypass a Chinese veto via the UN General Assembly, deploy UN patrol boats, and sue China before the ICJ for damages to the Kalayaan Islands.

Issues:

  • Whether a sitting President is immune from suit in a petition for mandamus.
  • Whether mandamus lies to compel discretionary foreign‐affairs or defense decisions of the President.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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