Facts
On December 12, 2018, President Rodrigo Duterte requested Congress to further extend the declaration of Martial Law and the suspension of the privilege of the writ of habeas corpus in the entire Mindanao for another year, from January 1 to December 31, 2019, citing the continuing rebellion of local terrorist groups such as the Abu Sayyaf Group (ASG), Bangsamoro Islamic Freedom Fighters (BIFF), Daulah Islamiyah (DI), ISIS-affiliated groups, and communist insurgents led by the CPP-NPA-NDF. Acting under Article VII, Section 18 of the 1987 Constitution, Congress approved the President's request through a joint resolution, finding that rebellion persisted and that public safety required the extension.
Several petitions were thereafter filed by legislators, party-list representatives, lawyers, and private citizens, arguing that the third extension lacked sufficient factual basis because the Marawi Siege had already ended and there was no actual rebellion throughout the whole of Mindanao. They further contended that the extension violated Article VII, Section 18 of the Constitution, which allows martial law and the suspension of the privilege of the writ of habeas corpus only in case of invasion or rebellion and when public safety requires it. Petitioners also raised alleged human rights violations committed during the implementation of martial law as grounds for invalidating the extension.
Issue
Whether Congress gravely abused its discretion in approving the third extension of Martial Law and the suspension of the privilege of the writ of habeas corpus in Mindanao under Article VII, Section 18 of the 1987 Constitution, and whether the President had sufficient factual basis to determine that rebellion persisted and public safety required the continued extension.
Held
No. The Supreme Court dismissed the consolidated petitions and upheld the constitutionality of the third extension. The Court ruled that the President had sufficient factual basis to conclude that rebellion continued in Mindanao. It explained that under Article VII, Section 18, the President is not required to establish rebellion beyond reasonable doubt; rather, the determination is based on probable cause, or evidence reasonably showing that rebellion exists and that public safety necessitates the extension. The Court emphasized that judicial review is limited to determining the sufficiency of the factual basis, not the correctness or wisdom of the President's decision. The reports submitted to Congress demonstrated that terrorist and rebel groups remained capable of launching attacks, recruiting members, and threatening public safety, thereby justifying the extension. The Court likewise reiterated that rebellion, as defined under Article 134 of the Revised Penal Code, consists of a public uprising and taking up arms against the Government to remove any part of Philippine territory from its allegiance or to deprive the President or Congress of their powers, and that the continuing activities of these armed groups satisfied these elements.
The Court further held that the alleged human rights violations during the implementation of martial law did not invalidate the extension because such claims must be resolved in separate judicial or administrative proceedings. It stressed that a declaration of martial law does not suspend the operation of the Constitution, civil courts, or the Bill of Rights, consistent with Article VII, Section 18. The Constitution itself imposes safeguards by limiting the duration of martial law, requiring congressional approval for any extension, and authorizing Supreme Court review of its factual basis. Finding that these constitutional requirements were satisfied and that public safety continued to demand extraordinary measures, the Court sustained the extension of martial law and the suspension of the privilege of the writ of habeas corpus in Mindanao
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