FACTS:

On November 24, 2009, a day after the Maguindanao massacre, President Gloria Macapagal-Arroyo issued Proclamation 1946, placing the Provinces of Maguindanao and Sultan Kudarat and the City of Cotabato under a state of emergency. She also issued Administrative Order 273 (AO 273) "transferring" supervision of the Autonomous Region of Muslim Mindanao (ARMM) from the Office of the President to the Department of Interior and Local Government (DILG). This was later amended by Administrative Order 273-A (AO 273-A) by "delegating" instead of "transferring" supervision of the ARMM to the DILG. Petitioners, ARMM officials, filed a petition for prohibition, claiming that the President's issuances encroached on the ARMM's autonomy and violated the principle of local autonomy and the Constitution. They argued that the President had no factual basis for declaring a state of emergency and that the deployment of troops and the taking over of the ARMM was an invalid exercise of emergency powers. They sought to have the issuances declared unconstitutional and for the respondents to be enjoined from implementing them. The Office of the Solicitor General (OSG) defended the President's issuances, stating that they were meant to restore peace and order and did not authorize a take over of the ARMM.

ISSUES:

1. Whether or not Proclamation 1946 and AOs 273 and 273-A violate the principle of local autonomy

2. Whether or not President Arroyo invalidly exercised emergency powers

3. Whether or not the President had factual bases for her actions.

RULING:

1. The Court dismissed the petition.

PRINCIPLES:

• Principle of Local Autonomy

• Calling Out Power of the President as Commander-in-Chief

• Delegation of Supervisory Powers

• Exercise of Emergency Powers

• Factual Basis for Presidential Actions