Case Digest (G.R. No. L-38415) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 23, 2017, President Rodrigo Duterte issued Proclamation No. 216, placing the entire island group of Mindanao under martial law and suspending the privilege of the writ of habeas corpus for up to sixty days to address the Maute-Abu Sayyaf siege of Marawi City. Within forty-eight hours, he reported to Congress the factual basis for his action. Congress initially supported the proclamation and, at the President’s request, twice extended its effectivity to December 31, 2017 and December 31, 2018. On December 6, 2018, Secretary of National Defense Delfin Lorenzana and AFP Chief of Staff Carlito Galvez, Jr. recommended a further one-year extension of Proclamation No. 216 “to finally put an end” to continuing rebellion by DAESH-inspired groups (Abu Sayyaf, Bangsamoro Islamic Freedom Fighters, Daulah Islamiyah), and the Communist Party of the Philippines-New People’s Army, which had carried out numerous bombings, kidnappings, ambuscades, arson attacks and assassinations in Mindan Case Digest (G.R. No. L-38415) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial Martial Law Declaration
- On May 23, 2017, President Duterte issued Proclamation No. 216, declaring martial law and suspending the writ of habeas corpus in the whole of Mindanao for 60 days due to the Maute-ASG siege of Marawi City.
- The President’s May 25, 2017 Report to Congress cited Maute-ASG attacks—checkpoint seizures, hospital takeovers, arson, mass jailbreak, and hoisting of an ISIS flag—as factual bases.
- First and Second Extensions
- On July 22, 2017, Congress (joint session) adopted Resolution of Both Houses No. 2, extending martial law to December 31, 2017.
- On December 13, 2017, Congress adopted Resolution of Both Houses No. 4, extending martial law to December 31, 2018, after President Duterte’s request and updated military/police assessments.
- Third Extension Request and Legislative Action
- On December 4–6, 2018:
- Defense Secretary Lorenzana, AFP Chief of Staff Galvez, Jr., and PNP Chief Albayalde recommended a one-year extension based on continuing rebellion by ISIS-inspired groups (ASG, BIFF, DI) and communist insurgents (CPP-NPA).
- President Duterte’s letter to Congress cited bombings (Lamitan, Basilan; Isulan, Sultan Kudarat; Apopong, Gen. Santos), kidnap-for-ransom by ASG, over 342 violent incidents by communist terrorists, 87 military casualties, and ₱156 million property damage.
- On December 12, 2018, Congress adopted Resolution No. 6, extending Martial Law and suspension of the writ for January 1 to December 31, 2019.
- Four consolidated Petitions were filed under Section 18, Article VII of the Constitution, questioning the sufficiency of factual basis for the third extension and seeking TRO/WPI.
Issues:
- Sufficiency of Factual Basis
- Does rebellion persist in Mindanao as required by Article 134, RPC?
- Does public safety still require martial law and suspension of the writ?
- Constitutional Limits on Extensions
- Are there limits on the number or duration of successive extensions?
- Has Proclamation No. 216 become functus officio with the end of the Marawi siege?
- Political Question Doctrine
- Is the manner by which Congress conducted the extension a non-justiciable political question?
- Injunctive Relief
- Should a TRO/WPI issue to enjoin implementation of the third extension?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)