Title
Marcos vs. Manglapus
Case
G.R. No. 88211
Decision Date
Oct 27, 1989
The Philippine Supreme Court upheld President Aquino's decision to bar the Marcoses' return, citing national security concerns and recognizing presidential residual powers to protect public welfare.

Case Digest (G.R. No. 88211)
Expanded Legal Reasoning Model

Facts:

  • Parties and Prior Proceedings
    • Petitioners: Ferdinand E. Marcos, Imelda R. Marcos, their children and relatives, and Philippine Constitution Association (PHILCONSA).
    • Respondents: Executive officials of the Aquino administration, including the President, Secretary of Foreign Affairs, and others.
    • September 15, 1989 Decision: By an eight-to-seven vote, the Supreme Court dismissed the petition, upholding the President’s exercise of discretion in barring the return of Marcos and his family as posing a threat to national interest and welfare.
  • Supervening Event and Motion for Reconsideration
    • Death of Ferdinand E. Marcos: He died on September 28, 1989 in Honolulu, Hawaii. President Aquino publicly barred the return of his remains until further government decision.
    • Motion for Reconsideration (October 2, 1989): Petitioners contended that the bar on return violated the inherent right of citizens to return, was arbitrary, and lacked constitutional basis. They sought issuance of travel documents for the family and enjoinment of the ban on the remains.
  • Government’s Comment and Court Resolution
    • Solicitor General’s Comment: Argued the motion was moot as to the deceased Marcos and characterized the invoked “right to return” as a guise for destabilization efforts.
    • Court’s Resolution: The Supreme Court denied the motion for reconsideration for lack of compelling reasons, ruling that the death did not alter the factual scenario, threats persisted, and Mrs. Marcos’s statements reinforced destabilization fears.

Issues:

  • Whether the death of Ferdinand E. Marcos as a supervening event warrants reconsideration of the prior decision.
  • Whether the President under the 1987 Constitution possesses authority to bar the return of a Filipino citizen—and the remains of a deceased citizen—when such return is deemed a threat to national interest and welfare.
  • Whether the President acted arbitrarily or with grave abuse of discretion in barring the return of Marcos, his family, and his remains.
  • Whether petitioners met their burden of showing compelling reasons for reconsideration.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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