Title
Lagman vs. Pimentel III
Case
G.R. No. 235935
Decision Date
Feb 6, 2018
President Duterte declared martial law in Mindanao in 2017 to address rebellion; Congress extended it, upheld by the Court as constitutional.

Case Digest (G.R. No. 235935)
Expanded Legal Reasoning Model

Facts:

  • Background and Context
    • A state of martial law was declared in Mindanao on May 23, 2017, through Proclamation No. 216 by President Rodrigo R. Duterte, in response to rebellion by the Maute Group and Abu Sayyaf Group (ASG), which included taking over parts of Marawi City and establishing checkpoints, burning facilities, and hoisting ISIS flags.
    • The declaration initially lasted 60 days and was extended by Congress until December 31, 2017, following the President's request and a joint session approval.
    • On December 8, 2017, the President requested further extension of martial law and suspension of the writ of habeas corpus for one year (January 1 to December 31, 2018), citing persistent rebellion and threats from remnants of terrorist groups and other armed lawless groups, and also including the New People’s Army (NPA).
    • On December 13, 2017, Congress, in a joint session, approved the extension by majority vote, citing ongoing threats and the need for public safety.
  • Petitions and Legal Challenge
    • Four consolidated petitions were filed before the Supreme Court challenging the constitutionality of the extension, questioning:
      • Sufficiency of factual basis for the extension, arguing that the Maute rebellion had ended with Marawi’s liberation;
      • Scope and duration of the extension, contending it was excessive and possibly perpetual;
      • Procedural aspects, including the manner and speed of Congress’ approval;
      • Alleged human rights violations resulting from martial law; and
      • President Duterte’s inclusion as respondent and the doctrine of presidential immunity.
    • Respondents, through the Office of the Solicitor General (OSG), argued that the extension was constitutional, backed by the President’s and military’s factual findings, and that Congress acted within its discretion and rules.
  • Judicial Proceedings and Oral Arguments
    • The petitions invoked the Supreme Court’s special jurisdiction under Section 18, Article VII of the Constitution to review the sufficiency of factual basis of martial law declarations and extensions.
    • Several hearings and oral arguments were conducted, where the AFP Chief of Staff, Defense Secretary, and other officials presented data on ongoing rebel activities, recruitment efforts, terrorist threats, and security assessments showing persisting rebellion and threats to public safety.
    • Petitioners highlighted alleged insufficiency and inaccuracy of information, argued for stricter scrutiny and limited extension, and expressed concerns over potential abuse and erosion of civil liberties.
    • Respondents emphasized the ongoing threats from various armed groups, military necessity, and constitutionality of Congress’ extension and procedures.

Issues:

  • Whether there is sufficient factual basis to justify the extension of the proclamation of martial law and suspension of the writ of habeas corpus in the whole of Mindanao for one year from January 1 to December 31, 2018.
  • Whether the Congress acted within its constitutional discretion and due process in approving the martial law extension, including manner and duration.
  • Whether the petitioners have the legal standing and whether the inclusion of President Duterte as respondent violates the doctrine of presidential immunity.
  • The extent and scope of the Supreme Court’s judicial power and standard of review in assessing the sufficiency of factual basis for the martial law extension.
  • Whether martial law was properly and effectively limited, or whether the extension enables potential abuse and violation of civil liberties.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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