Case Digest (G.R. No. 231671)
Facts:
Padilla v. Congress, G.R. Nos. 231671 and 231694, July 25, 2017, the Supreme Court En Banc, Leonardo-De Castro, J., writing for the Court.The consolidated petitions challenged Congress’s failure or refusal to convene in joint session to deliberate on Proclamation No. 216 (May 23, 2017) in which President Rodrigo R. Duterte declared martial law and suspended the privilege of the writ of habeas corpus in Mindanao for up to sixty (60) days. Petitioners in G.R. No. 231671 (Padilla et al.) filed a Petition for Mandamus (June 6, 2017) seeking an order compelling Congress to convene in joint session and vote on Proclamation No. 216; petitioners in G.R. No. 231694 (Tanada et al.) filed a Petition for Certiorari and Mandamus (June 7, 2017) alleging grave abuse of discretion and likewise seeking a writ compelling Congress to convene jointly.
On May 25, 2017—within forty‑eight hours of the proclamation—President Duterte transmitted his report to the Senate (through Senate President Aquilino “Koko” Pimentel III) and the House (through House Speaker Pantaleon D. Alvarez). The Senate held a closed briefing on May 29 and on May 30 considered two resolutions: P.S. Resolution No. 388 (supporting the proclamation) and P.S. Resolution No. 390 (calling for a joint session). The Senate adopted what became Senate Resolution No. 49 expressing support for Proclamation No. 216; P.S. No. 390 failed. The House, after a closed briefing on May 31 as Committee of the Whole, passed House Resolution No. 1050 expressing full support for the proclamation and rejected a proposal to call a joint session. Congress therefore acted separately and did not adopt a concurrent resolution convening both Houses.
Respondents (the Congress of the Philippines, represented by the Office of the Solicitor General, and separately the Senate and its President) filed consolidated comments arguing lack of standing, nonjusticiability (political question), and that Article VII, Section 18 of the 1987 Constitution does not impose a mandatory duty to convene in joint session except when the Congress is to vote jointly to revoke or extend the proclamation. Petitioners countered that Article VII, Section 18 requires Congress to convene and deliberate jointly and that mandamus lies to compel this ministerial constitutional duty.
While the petitions were pending the original sixty‑day period expired; ...(Subscriber-Only)
Issues:
- Does the Supreme Court have jurisdiction over these consolidated petitions?
- Do the petitioners satisfy the requisites for judicial review (standing, actual case or controversy, ripeness)?
- Under Article VII, Section 18 of the 1987 Constitution, is Congress required to convene in joint session automatically to deliberate and vote whenever the President proclaims martial law or suspends the privilege of the writ of habeas corpus?
- Is issuance of a writ of mandamus or certiorari appropriate to compel Congress ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)