Case Digest (G.R. No. 231671) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Padilla et al. v. Congress of the Philippines (G.R. Nos. 231671 & 231694, July 25, 2017), petitioners led by Alexander A. Padilla, former Senator Wigberto E. Taáada and co-petitioners challenged the refusal of Congress to convene in a joint session to deliberate on Proclamation No. 216, which President Rodrigo R. Duterte issued on May 23, 2017 declaring a state of martial law and suspending the privilege of the writ of habeas corpus throughout Mindanao for not more than sixty days. Within forty-eight hours, the President transmitted a report to the Senate President and House Speaker, but each chamber thereafter separately reviewed the proclamation under its own rules. The Senate adopted a resolution supporting Proclamation No. 216 and rejected a proposal for joint session, while the House likewise affirmed support and refused to convene jointly. Petitioners filed consolidated petitions for mandamus and certiorari before the Supreme Court, claiming a constitutional duty under ... Case Digest (G.R. No. 231671) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proclamations
- Petitioners in G.R. No. 231671 (Padilla et al.) and G.R. No. 231694 (Taáda et al.) challenged Congress’ inaction.
- On May 23, 2017, President Duterte issued Proclamation No. 216:
- Declared martial law and suspended the writ of habeas corpus in Mindanao for up to 60 days.
- Required presidential report to Congress within 48 hours.
- Congressional Proceedings
- May 25, 2017: Transmittal of the President’s Report to Senate President Pimentel and House Speaker Alvarez.
- May 29–30, 2017:
- Closed‐door briefings for Senate and House security officials.
- Senate introduced two resolutions—one supporting Proclamation No. 216 (adopted; 17–5), one calling for joint session (rejected; 9–12).
- May 31, 2017: House, sitting as Committee of the Whole, adopted a resolution expressing full support and rejected a proposal for joint session.
- July 22, 2017: Congress convened jointly and, by 261–18 votes, extended martial law and habeas suspension until December 31, 2017.
Issues:
- Jurisdiction
- Standing and ripeness
- Constitutional duty under Article VII, Section 18:
- Whether Congress must convene in joint session to deliberate and vote on martial law/habeas suspension.
- Scope of “voting jointly” requirement.
- Remedies
- Availability of mandamus.
- Availability of certiorari.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)