Case Digest (G.R. No. 159085) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the early hours of July 27, 2003, some 323 junior officers and enlisted personnel of the Armed Forces of the Philippines stormed the Oakwood Premiere apartments in Makati City in what became known as the Oakwood mutiny, publicly demanding the resignation of President Gloria Macapagal-Arroyo, the Secretary of National Defense, and the Chief of the Philippine National Police. Later the same day, President Arroyo issued Proclamation No. 427 declaring a state of rebellion and General Order No. 4, invoking her calling out power under Section 18, Article VII of the 1987 Constitution to direct the AFP and PNP to suppress the uprising “with due regard to constitutional rights.” After hours of negotiations, the mutineers surrendered and returned to barracks by the evening of July 27. President Arroyo lifted the rebellion proclamation only on August 1, 2003, through Proclamation No. 435. In the interim, four petitions (G.R. Nos. 159085, 159103, 159185 and 159196) were filed directly wi Case Digest (G.R. No. 159085) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation of Petitions
- Four petitions filed before the Supreme Court:
- G.R. No. 159085 by Sanlakas (Rep. J.V. Bautista) and Partido ng Manggagawa (Rep. Renato Magsumbo)
- G.R. No. 159103 by Social Justice Society officers/members (Alcantara, Albano, Gorospe, Sandoval, Mapile)
- G.R. No. 159185 by House Representatives Suplico, Padilla, Lobregat, Amin, Mitra, Talino-Santos, Yumul-Hermida
- G.R. No. 159196 by Senator Aquilino Q. Pimentel, Jr.
- Common Respondents: President Gloria Macapagal-Arroyo, Executive Secretary, Secretaries of Defense, Justice and DILG, AFP and PNP Chiefs
- The Oakwood Incident and Presidential Actions
- July 27, 2003 – some 323 junior AFP officers and enlisted men occupy Oakwood Premiere apartments in Makati, citing corruption and demanding resignations of the President, DND and PNP chiefs
- President issues at 1:00 PM Proclamation No. 427 declaring a “state of rebellion” and General Order No. 4 calling out the AFP and PNP to suppress it
- By 11:00 PM the same day, the occupants surrender; subsequent searches, seizures and in-custody interrogations ensue in Makati and surrounding staging areas
- Subsequent Developments
- August 1, 2003 – President lifts the “state of rebellion” via Proclamation No. 435
- Petitions challenge Proclamation No. 427 and General Order No. 4 on grounds of constitutional grant of power, standing, report requirements, and alleged usurpation of congressional/emergency powers
Issues:
- Do Proclamation No. 427 and General Order No. 4 exceed Presidential powers under Section 18, Article VII of the 1987 Constitution?
- Are the petitions rendered moot by Proclamation No. 435 and, if so, does the “capable of repetition, yet evading review” exception apply?
- Which petitioners possess legal standing to challenge the proclamations and orders?
- Does the declaration of a “state of rebellion” trigger the report requirements applicable to martial law or suspension of the writ of habeas corpus?
- Can the proclamations be deemed an exercise of “emergency powers” requiring prior congressional authorization under Section 23(2), Article VI?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)