Case Summary (G.R. No. 147780)
Lifting of Proclamation and Mootness
On May 6, 2001 the President lifted the state of rebellion. The Court held that the petitions challenging the proclamation and the legality of warrantless arrests had thus become moot and academic, absent any ongoing state of rebellion to sustain the executive’s extraordinary measures.
Availability of Adequate Remedies
The DOJ affirmed that regular warrants of arrest would be secured for all acts related to the May 1 events. Petitioners retained full access to ordinary remedies: preliminary investigations under Rule 112; inquest proceedings; delivery to proper judicial authorities within time limits under Art. 125, RPC; habeas corpus; actions for arbitrary detention; and civil damages under Art. 32, Civil Code.
Jurisdictional and Justiciability Defects
Mandamus and prohibition were deemed inappropriate because no criminal complaints had yet been filed (prematurity) and petitioners’ claimed fear of imminent warrantless arrest did not deprive them of adequate legal remedies. Laban ng Demokratikong Pilipino lacked personal stake as a juridical entity not subject to arrest.
Scope of Executive Power and Rule of Law
The Court reaffirmed that warrantless arrests outside Rule 113, Sec. 5 exceptions violate the Constitution’s guarantee against unreasonable seizures (Art. III, Sec. 2). A state of rebellion declaration does not suspend the writ or constitutional protection; it merely notifies that the
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Procedural Background
- On May 1, 2001, President Gloria Macapagal-Arroyo issued Proclamation No. 38 declaring a state of rebellion in the National Capital Region and General Order No. 1 directing the AFP and PNP to suppress it.
- Four related petitions were filed before the Supreme Court:
• G.R. No. 147780 by Lacson, Aquino, and Mancao for prohibition, injunction, mandamus, and habeas corpus.
• G.R. No. 147781 by Defensor-Santiago for mandamus and review of the factual basis for suspension of the writ of habeas corpus.
• G.R. No. 147799 by Lumbao for prohibition and injunction.
• G.R. No. 147810 by Laban ng Demokratikong Pilipino for certiorari and prohibition. - All petitions challenged the validity of the state of rebellion proclamation and the authority to make warrantless arrests thereunder.
Factual Context
- An “angry and violent mob,” allegedly armed with explosives, firearms, bladed weapons, clubs, stones, and other deadly instruments, attempted to storm Malacañang on May 1, 2001.
- Proclamation No. 38 and General Order No. 1 were issued to quell the uprising; warrantless arrests of suspected leaders and promoters followed.
- On May 6, 2001, the President lifted the declaration of rebellion in Metro Manila.
Petitioners’ Contentions
- They argued that the proclamation had no factual or legal basis and that it functioned as a pretext for warrantless arrests.
- Lacson et al. sought to enjoin criminal proceedings, nullify hold-departure orders, and secure habeas corpus relief.
- Defensor-Santiago sought mandamus to prevent a suspension of the privilege of the writ without factual review.
- Lumbao asserted that the declaration violated separation of powers and usurped judicial functions.
- LDP claimed an abstract right to free expression and assembly, seeking certiorari and prohibition.
Respondents’ Assertions and Undertakings
- The Justice Department denied issuing orders to arrest specific persons; only general instructions were given to enfor