G.R. No. 231658 - Lagman vs. Medialdea

1987 Philippine Constitution, Article VII, Section 18 (Commander‐in‐Chief powers; suspension of the writ; martial law)
Revised Penal Code definitions of rebellion (elements: public uprising, taking up of arms, purpose to remove allegiance to Government or deprive Chief Executive/Congress of powers)

The Court initially upheld Proclamation No. 216 as constitutional and based on sufficient factual bases.
Petitioners filed separate Motions for Reconsideration contesting:
1. Sufficiency of factual bases for declaring martial law/suspending the writ
2. Parameters applied to evaluate sufficiency

Proclamation No. 216 expired automatically at 60 days; Congress extended martial law under Resolution of Both Houses No. 11, a distinct act.
Challenges to Proclamation No. 216 are moot and academic once it expired.
A case is moot when supervening events render declaration of rights of no practical value.

Judicial review under Section 18 is confined to “sufficiency of factual basis,” not to accuracy.
Parameters for sufficiency:
1. Actual invasion or rebellion
2. Public safety requires martial law or suspension of the writ (must concur)
3. Probable cause for the President to believe invasion or rebellion exists (more likely than not)
The Court examines the totality of facts in proclamation and report, not piecemeal.

Constitution requires sufficiency, not precision or absolute correctness of facts.
Presidents rely on intelligence reports; impractical to verify every detail under emergency.
Inaccuracies in some factual recitals do not invalidate declaration if other facts support actual invasion/rebellion and public safety need.
The standard of proof is probable cause, not absolute truth.

Martial law/suspension must be limited to territory where “actual rebellion” exists, as defined by Revised Penal Code.
Proclamation No. 216 cited only Marawi City rebellion; extension to whole Mindanao lacked constitutional basis.
Removal of “imminent danger” from 1987 Constitution means rebellion must already exist in each area before martial law is declared there.
Votes to partially grant reconsideration and strike down Proclamation No. 216 outside Marawi City.

On May 23, 2017, President Duterte issued Proclamation No. 216 declaring martial law and suspending the privilege of the writ of habeas corpus throughout Mindanao for 60 days.
Petitioners in three consolidated cases challenged the sufficiency of the factual bases cited by the President and the parameters used by the Court in its initial July 4, 2017 Decision upholding the Proclamation as constitutional.
The Office of the Solicitor General filed a Comment supporting the sufficiency of the factual bases and explaining that the current martial law extension rests on Congress’s Resolution of Both Houses No. 11 adopted July 22, 2017—not on Proclamation No. 216.
Petitioners filed separate Motions for Reconsideration, reiterating two main contentions: (1) that the President lacked sufficient factual basis to declare martial law and suspend the writ; and (2) that the Court applied incorrect parameters in reviewing those factual bases.

July 4, 2017: En Banc Supreme Court issued a Decision finding Proclamation No. 216 to be backed by sufficient factual bases and constitutional parameters.
Petitioners filed Motions for Reconsideration.
December 5, 2017: Supreme Court En Banc rendered a Resolution denying all Motions for Reconsideration for mootness and lack of merit. Judgment was immediately entered and notice furnished on December 14, 2017.

Whether the factual bases for Proclamation No. 216 were sufficient under Section 18, Article VII of the 1987 Constitution.
Whether the Court employed correct parameters in reviewing those factual bases.
Whether the challenge is rendered moot by the expiration of Proclamation No. 216.

The expiration of Proclamation No. 216 on July 23, 2017 rendered the question of its factual sufficiency moot and academic.
Subsequent martial law currently in force in Mindanao is based on Congress’s Resolution of Both Houses No. 11, a joint executive-legislative act distinct from the President’