G.R. No. 231658 - Lagman vs. Medialdea

On May 23, 2017, President Rodrigo Roa Duterte issued Proclamation No. 216, declaring martial law and suspending the privilege of the writ of habeas corpus in the whole Mindanao group of islands for 60 days, effective immediately.
The declaration responded to escalating terrorism and violence, particularly the siege of Marawi City by the Maute terrorist group and allied armed factions such as the Abu Sayyaf Group (ASG).
The President submitted a Report to Congress within 48 hours outlining the factual basis for the declaration, citing:

Series of violent acts by Maute Group, including attack on military outpost in Butig (Feb. 2016) and mass jail break in Marawi City (Aug. 2016).
On the day of declaration, armed takeover of a hospital, setting up of checkpoints, burning of government and private facilities, hoisting ISIS flags, and taking hostages in Marawi City.
Interference with government forces, power outage, road blockades, and occupation of multiple barangays.
The groups’ declared intention to establish an ISIS wilayat (province) in Mindanao.

Both Houses of Congress expressed full support for Proclamation No. 216 after hearing briefings from the Executive Department and military officials.
Three consolidated petitions (Lagman, Cullamat, and Mohamad) challenged the sufficiency of the factual basis of the declaration, claiming absence of actual rebellion, reliance on false information, untimely or inadequate consultation with military authorities, and overbroad application of martial law to the entire Mindanao.

No actual rebellion existed in Mindanao; terrorism acts do not equate to rebellion.
President’s report contains false and exaggerated accounts (e.g., hospital takeover, school burnings).
No prior consultation with military on martial law.
The concept of imminent danger no longer valid ground.

Martial law is a last resort; President must exhaust less severe powers first.
Court’s review should include wisdom of President’s actions, not mere arbitrariness.
Seeks compelling evidence from the government for factual basis.

Respondents maintain that the President had credible and sufficient factual basis for his proclamation.
Emphasized the President’s prerogative and sole authority under the Constitution to declare martial law when public safety requires it.
Argued Court’s review power is sui generis, limited to factual sufficiency, with deference to President’s judgment informed by intelligence reports.
Asserted that after-proclamation facts are mostly irrelevant to the initial sufficiency of the factual basis.
Maintained burden of proof lies on petitioners to demonstrate insufficiency.
Presented intelligence and military reports at closed sessions supporting existence of armed rebellion in Mindanao with ISIS links.

Whether the consolidated petitions constitute the “appropriate proceeding” to invoke the Court’s judicial review power under the third paragraph, Section 18, Article VII of the 1987 Constitution.
The nature and scope of the Court’s power of review: factual sufficiency versus arbitrariness or grave abuse of discretion.
Whether the burden of proof lies with the President/government or with the petitioners.
Whether the Court’s review power is independent of Congress’s power to revoke the proclamation.
Whether the President must consult or obtain recommendation from the Secretary of National Defense or other military officials before declaring martial law.
The timing for the Court’s review—whether it is limited to facts existing at time of proclamation or includes subsequent events.
Whether the President must choose among his “graduated” powers sequentially or may invoke martial law directly.
Whether Proclamation No. 216 is overbroad or vague, particularly with respect to inclusion of “other rebel groups” and lack of operational guidelines.
Whether the armed hostilities constitute sufficient basis for actual rebellion warranting martial law or suspension of writ in entire Mindanao.
Whether acts of terrorism equate to rebellion under constitutional standards.
Whether nullifying Proclamation No. 216 would also nullify Proclamation No. 55 (state of national emergency) or other actions such as calling out the armed forces.