Case Digest (G.R. No. 238467) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 238467, decided on February 12, 2019, en banc, residents of Boracay Island—Mark Anthony V. Zabal, a sandcastle artisan, and Thiting Estoso Jacosalem, a tricycle driver—together with occasional visitor Odon S. Bandiola, petitioned for prohibition and mandamus, seeking to enjoin and nullify Proclamation No. 475 issued by President Rodrigo R. Duterte on April 26, 2018. The President had declared a state of calamity in Barangays Balabag, Manoc-Manoc, and Yapak (Boracay Island) and ordered its closure as a tourist destination for six months (April 26–October 25, 2018). They alleged loss of livelihood, deprivation of their right to travel and earn a living, and asserted that no enabling law authorized such closure. They invoked their rights under the 1987 Constitution and sought immediate injunctive relief. Respondents—the President, his Executive Secretary, and the Interior and Local Government Secretary—filed comments, defending the proclamation as a valid exercise of po Case Digest (G.R. No. 238467) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- The Parties and Petition
- Petitioners Mark Anthony V. Zabal (sandcastle maker), Thiting Esteso Jacosalem (driver), and Odon S. Bandiola (non-resident visitor) earn their living from tourism in Boracay.
- They filed a special civil action for Prohibition and Mandamus with Application for Temporary Restraining Order, Preliminary Injunction, and/or Status Quo Ante Order against President Rodrigo R. Duterte, Executive Secretary Salvador C. Medialdea, and DILG Secretary Eduardo M. AAo.
- They contend that the island’s scheduled rehabilitation and closure violate their constitutional rights to travel and due process.
- Boracay Closure and Rehabilitation
- President Duterte publicly labeled Boracay a “cesspool” in February 2018 and announced plans for a six-month shutdown.
- In a Cabinet meeting on April 4, 2018, he ordered total closure starting April 26, 2018; around 630 police and military personnel were deployed.
- DILG issued draft guidelines restricting entry to residents and barring tourists; swimming and business operations were suspended.
- On April 26, 2018, Proclamation No. 475 formally declared a state of calamity in Boracay and ordered the island’s closure until October 25, 2018 to facilitate environmental rehabilitation.
- Procedural History
- The Supreme Court required respondents to comment on April 26 and June 5, 2018; respondents filed a Consolidated Comment on July 30, 2018; petitioners replied on October 12, 2018.
- Boracay reopened on October 26, 2018.
- The Court consolidated issues of legality and constitutionality of Proclamation 475 under Rule 65 of the Rules of Court.
Issues:
- Whether Prohibition and Mandamus are proper remedies to challenge an executive proclamation on constitutional grounds.
- Whether Proclamation No. 475 is a valid exercise of legislative power by the President.
- Whether Proclamation No. 475 improperly restricts the constitutional right to travel without a law.
- Whether the island’s closure deprived petitioners of their right to work and earn a living without due process.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)