Case Summary (G.R. No. 190293)
Events Leading to Proclamation
In response to the heinous killing of civilians known as the Maguindanao massacre, President Arroyo issued Proclamation No. 1946 on November 24, 2009, declaring a state of emergency in Central Mindanao to prevent further violence. Subsequently, on December 4, 2009, she issued Proclamation No. 1959, citing threats from armed groups and declaring martial law in Maguindanao.
Congressional Actions
By December 6, 2009, President Arroyo submitted her report to Congress concerning Proclamation No. 1959, as mandated by Section 18, Article VII of the 1987 Philippine Constitution. Congress convened on December 9, 2009, to review the President's action. However, Proclamation No. 1959 was lifted by Arroyo on December 12, thereby restoring the writ of habeas corpus before Congress could act.
Legal Grounds for Petition
The petitioners contested the constitutionality of Proclamation No. 1959, arguing that it lacked a sufficient factual basis as required by the Constitution. They raised concerns regarding violations of civil rights and questioned whether the condition for declaring martial law—actual rebellion or invasion—was genuinely present.
Court’s Rationale
The Supreme Court found that the petitions were moot, as the proclamation was promptly lifted, thereby removing any justiciable controversy. The majority opinion emphasized the need for deference to the executive and legislative branches, given that the President’s action was never reviewed by Congress due to the sudden lifting of the proclamation.
Political Questions and Constitutional Review
The Court delineated that the President acts within a political framework when declaring martial law, sharing powers with Congress regarding the validation of such proclamations. Therefore, the emergency action taken by the President could only be reviewed if Congress failed in its duty to assess it.
Findings on “Rebellion”
Justice Carpio, dissenting, highlighted admissions from Executive Secretary Ermita and others during congressional sessions that indicated there was no actual rebellion occurring in Maguindanao but rathe
...continue readingCase Syllabus (G.R. No. 190293)
Background and Context
- The case involves the constitutionality of Presidential Proclamation No. 1959 issued on December 4, 2009, wherein President Gloria Macapagal-Arroyo declared martial law and suspended the privilege of the writ of habeas corpus in Maguindanao Province, except for certain areas of the Moro Islamic Liberation Front (MILF).
- The proclamation was a response to the gruesome Maguindanao massacre on November 23, 2009, where 57 innocent civilians, including family members of political figure Esmael Mangudadatu and media personnel, were killed by armed men believed to be led by the Ampatuan family.
- The Government cited the presence of heavily armed groups in Maguindanao, closure of provincial government offices, and the inability of local authorities to enforce the law as grounds for martial law.
- Prior to martial law declaration, Proclamation No. 1946 was issued on November 24, 2009, declaring a state of emergency in Maguindanao, Sultan Kudarat, and Cotabato City to curb lawless violence.
Legal Issue
- The core legal question concerns the constitutionality of Proclamation No. 1959 under Section 18, Article VII of the 1987 Philippine Constitution, particularly whether there was a sufficient factual basis to justify the declaration of martial law and suspension of the writ.
- The case also explores whether the lifting of martial law by Proclamation No. 1963 on December 12, 2009, rendered the petitions moot.
- Ancillary issues include:
- Definition and scope of "rebellion" under the Constitution vis-à-vis the Revised Penal Code;
- Whether martial law allows warrantless arrests, searches, or seizures;
- The interplay of presidential, congressional, and judicial powers in reviewing martial law declarations.
Facts Established in the Case
- The massacre involved the killing and burial of 57 civilians, including members of the Mangudadatu family and numerous journalists, attributed to the Ampatuan clan.
- Local government offices and courts in Maguindanao were reported closed or incapacitated, impeding legal and governmental functions.
- Armed groups affiliated with the Ampatuans were documented, including possession of high-powered weapons, armored vehicles, and strategic deployment across the province.
- Martial law was declared citing the inability of the government to maintain peace and order, allegations of rebellion, and threats to public safety.
- President Arroyo submitted a required report to Congress within 48 hours, outlining the justification.
- Congress convened a joint session to review the proclamation but martial law was lifted eight days later.
- Local courts later dismissed rebellion charges against accused Ampatuans for lack of probable cause.
Constitutional and Legal Principles
- The President's power to declare martial law or suspend the writ of habeas corpus is conditioned by Section 18, Article VII of the 1987 Constitution which requires:
- Actual invasion or rebellion;
- Public safety must require such proclamation;
- Presidential report to Congress within 48 hours;
- Congress may revoke or extend the proclamation;
- Supreme Court's judicial review