Facts:
On November 23, 2009, 57 innocent civilians were brutally murdered in Maguindanao, Philippines, in what became known as the "Maguindanao massacre." In response, President Gloria Macapagal-Arroyo declared a state of emergency in Maguindanao, Sultan Kudarat, and Cotabato City on November 24, 2009, through Presidential Proclamation 1946.
- Declaration of Martial Law
On December 4, 2009, President Arroyo issued Presidential Proclamation 1959, declaring martial law and suspending the privilege of the writ of habeas corpus in Maguindanao. This was done to address the lawless violence and rebellion in the province.
On December 6, 2009, President Arroyo submitted a report to Congress, as required by Section 18, Article VII of the 1987 Constitution, detailing the factual basis for her actions. She cited the presence of heavily armed groups, the closure of government offices, and the use of unauthorized military equipment as reasons for the declaration.
Congress convened on December 9, 2009, to review the proclamation. However, before Congress could act, President Arroyo lifted martial law and restored the privilege of the writ of habeas corpus on December 12, 2009, through Presidential Proclamation 1963.
Multiple petitions were filed challenging the constitutionality of Proclamation 1959. The petitioners argued that the declaration of martial law and suspension of the writ of habeas corpus were unconstitutional and lacked sufficient factual basis.
Issues:
Whether the petitions challenging the constitutionality of Proclamation 1959 became moot after President Arroyo lifted martial law and restored the privilege of the writ of habeas corpus.
- Constitutionality of Proclamation 1959
Whether the declaration of martial law and suspension of the writ of habeas corpus in Maguindanao had sufficient factual basis and complied with constitutional requirements.
- Role of Congress and the Supreme Court
Whether the Supreme Court should review the constitutionality of Proclamation 1959, given that Congress had not yet acted on the matter before the proclamation was lifted.
Ruling:
Ratio: