Case Digest (G.R. No. 230861) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. Nos. 231658, 231771 & 231774, various petitioners—among them Representatives Edcel C. Lagman, Tomasito S. Villarín, Gary C. Alejano, Emmanuel A. Billones, Teddy Brawner Baguilat, Jr., human rights activists, civil society members, and certain Mindanao residents—challenged Proclamation No. 216 issued by President Rodrigo R. Duterte on May 23, 2017. That Proclamation declared martial law and suspended the privilege of the writ of habeas corpus over the entire Mindanao region for sixty days, citing an alleged armed rebellion in Marawi City by the Maute and Abu Sayyaf groups. The cases were brought directly to the Supreme Court en banc on petitions for prohibition, certiorari, and mandamus, and were initially decided on July 4, 2017, when the Court upheld the sufficiency of the factual bases and constitutionality of Proclamation No. 216 under the 1987 Constitution. Thereafter, the petitioners filed separate motions for reconsideration contesting the sufficiency of factual ba Case Digest (G.R. No. 230861) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proclamation No. 216 and initial Supreme Court Decision
- On May 23, 2017, President Rodrigo R. Duterte issued Proclamation No. 216 placing the entire Mindanao group of islands under martial law and suspending the privilege of the writ of habeas corpus for 60 days pursuant to Section 18, Article VII of the 1987 Constitution.
- On July 4, 2017, the Supreme Court, sitting en banc, rendered a Decision upholding Proclamation No. 216 as constitutional, finding that there were sufficient factual bases—derived from verified intelligence reports of the Armed Forces of the Philippines (AFP) and the Philippine National Police (PNP)—to warrant the declaration of martial law and suspension of the writ.
- Motions for Reconsideration and supporting pleadings
- Petitioners in three separate but consolidated cases (Lagman et al., Cullamat et al., and Mohamad et al.) filed Motions for Reconsideration challenging:
- The sufficiency of the factual bases for Proclamation No. 216.
- The parameters used by the Court in determining sufficiency.
- The Office of the Solicitor General (OSG) filed a Comment urging affirmation of the July 4 Decision’s findings.
Issues:
- Mootness
- Whether the petitions challenging the factual bases of Proclamation No. 216 remain justiciable after its 60-day term expired on July 23, 2017, particularly in light of Congress’s subsequent Resolution of Both Houses No. 11 (RBH No. 11) extending martial law in Mindanao.
- Scope and standard of judicial review under Section 18, Article VII
- Whether the Supreme Court correctly limited its review to the “sufficiency” of factual bases rather than their “accuracy.”
- What parameters govern the Court’s assessment of factual sufficiency in a proclamation of martial law and suspension of the privilege of the writ.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)