G.R. No. 214803 - Roldan vs. Spouses Barrios

Ferdinand E. Marcos, former Philippine President, declared Martial Law in 1972, leading to widespread human rights violations and plunder of state wealth.
Marcos was ousted through the People Power Revolution in 1986 and died in exile in 1989.
His remains were initially interred in a mausoleum in Batac, Ilocos Norte, following an agreement with the Philippine government in 1992, restricting burial to Batac with military honors befitting a major.

During the 2016 presidential campaign, Rodrigo R. Duterte promised to allow Marcos’ burial at the Libingan ng mga Bayani (LNMB).
After winning the presidency, Duterte verbally ordered the burial of Marcos at the LNMB on July 11, 2016.
Following this order, Defense Secretary Delfin Lorenzana issued a memorandum for AFP Chief of Staff General Ricardo Visaya to prepare for the burial and coordinate with the Marcos family.
The AFP issued directives to provide full military honors for Marcos.

Various petitioners—human rights victims, legislators, civic groups, and concerned citizens—filed multiple petitions questioning the legality and constitutionality of Marcos’ burial at the LNMB.
Grounds for petitions include allegations of grave abuse of discretion, violations of the 1987 Constitution, Republic Act No. 289 (National Pantheon Act), Republic Act No. 10368 (Human Rights Victims Reparation and Recognition Act), AFP regulations, and international law.

Originally established as the Republic Memorial Cemetery for World War II soldiers, renamed as Libingan ng mga Bayani in 1954 to honor war dead.
Declared a national shrine via Proclamation No. 208 (1967) and PD No. 105 (1973), under the administration of the Philippine Veterans Affairs Office (PVAO).
AFP Regulations (notably G 161-375) provide eligibility and disqualifications for interment therein, including disqualifications for dishonorably discharged personnel and those convicted of crimes involving moral turpitude.

The National Historical Commission of the Philippines (NHCP) published a study asserting Marcos’ military honors are fraught with myths and inconsistencies, opposing his burial at the LNMB.
Various international and local courts held Marcos responsible for gross human rights violations and plunder.
Republic Act No. 10368 recognizes human rights victims and affirms moral and legal obligations of the government to provide reparations and honor their sacrifices.

Whether President Duterte’s verbal order constitutes a justiciable controversy or a political question beyond judicial review.
Whether the petitioners have legal standing (locus standi) to file the petitions.
Whether the petitioners failed to exhaust administrative remedies and violated the hierarchy of courts doctrine by bringing the case directly to the Supreme Court.

Whether the Secretary of National Defense and AFP committed grave abuse of discretion in implementing President Duterte’s verbal order.
Whether the interment of Marcos at the LNMB violates:

The 1987 Constitution, including provisions on the rule of law, public office as a public trust, human rights, and faithful execution of laws;
Republic Act No. 289 (National Pantheon Act) regarding burial in the national pantheon;
Republic Act No. 10368 (Human Rights Victims Reparation and Recognition Act);
AFP Regulations on allocation of burial plots;
International human rights laws and related United Nations principles;
The requirement that public funds and property be used only for a legitimate public purpose.

Whether former President Marcos’s status (military awards, prior government posts) entitles him to burial at the LNMB despite his ouster and alleged crimes.
Whether the Marcos family waived the right to inter Marcos at the LNMB by prior agreements with the Philippine government.