Case Digest (G.R. No. 190293)
Facts:
Philip Sigfrid A. Fortun and Albert Lee G. Angeles, et al., G.R. Nos. 190293, 190294, 190301, 190302, 190307, 190356, 190380, March 20, 2012, the Supreme Court En Banc, Abad, J., writing for the Court. These consolidated petitions challenged Presidential Proclamation No. 1959 (Dec. 4, 2009), which declared martial law and suspended the privilege of the writ of habeas corpus in the Province of Maguindanao (except certain MILF areas); the petitions sought injunctive and declaratory relief and invoked certiorari/prohibition remedies.On November 23, 2009 a convoy bound for Shariff Aguak was ambushed and 57 persons were killed (the Maguindanao massacre). On November 24, 2009 President Gloria Macapagal‑Arroyo issued Proclamation No. 1946 declaring a state of emergency in parts of Central Mindanao. On December 4, 2009 she issued Proclamation No. 1959 declaring martial law and suspending habeas corpus in Maguindanao. She submitted a report to Congress on December 6, 2009 as required by Section 18, Article VII of the 1987 Constitution. Congress convened in joint session on December 9, 2009.
Before Congress acted, on December 12, 2009 the President issued Proclamation No. 1963, lifting martial law and restoring the writ in Maguindanao. Multiple petitioners filed separate suits in the Supreme Court (seeking TROs, writs of prohibition and certiorari under Rule 65 and related remedies) to challenge the constitutionality and factual basis of Proclamation No. 1959; the Court consolidated the petitions, appointed amici curiae, and required comments from the Office of the Solicitor General. Lower‑court proceedings related to the massacre included an information for rebellion filed in the RTC‑Cotabato, transfer of venue to RTC‑Quezon City, and on March 26, 2010 the RTC‑Quezon City dismissed the rebellion charge for lack of probable cause; the Department of Justice sought relief from the Court of Appeals, which denied certiorari on December 15, 2011.
The Supreme Court disposed of the consoli...(Pro-only)
Issues:
- Did President Arroyo’s issuance of Proclamation No. 1963 (lifting martial law and restoring the writ) render the consolidated petitions moot and academic?
- Do the petitioners have standing (locus standi) to challenge Proclamation No. 1959 as “any citizen” under Section 18, Article VII?
- Was there a sufficient factual basis for Proclamation No. 1959 under Section 18, Article VII to declare martial law and suspend the writ in Maguindanao?
- Does the term “rebellion” in Section 18, Article VII have the same meaning as rebellion defined in Article 134 of the Revised Penal Code?
- Does a declaration of martial law or suspension of the writ authorize warrantless arrests, searches, and seizures?
- Is the President’s power to declare martial law or suspend the writ a joint/sequential function with Congress such that, if the President lifts the proclamation before Congress acts, the Court has nothing to review?
- If the Supreme Court’s review conflicts with Congress’s decision on a proclamation, which decision prevails?
- Would the Court’s determination of the sufficiency of the...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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