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SANLAKAS v. EXECUTIVE SECRETARY SECRETARY ANGELO REYES

FACTS:

In July 2003, around 300 junior officers and enlisted men of the AFP occupied Oakwood Premiere apartments in Makati City, armed with firearms and explosives, to protest against corruption in the military and demand the resignation of top government officials. In response, the President issued Proclamation No. 427 and General Order No. 4, declaring a state of rebellion and directing the AFP and PNP to suppress the rebellion. After negotiations, the soldiers returned to barracks, and the state of rebellion was lifted on August 1, 2003. Several petitions challenging the validity of the presidential issuances were filed before the Supreme Court. The petitions argued that there was no sufficient factual basis for the declaration of a state of rebellion, that it violated citizens' constitutional rights, and that it was an exercise of emergency powers usurping Congress's authority. The Solicitor General argued that the case was moot, but the Court decided to address the constitutionality of the declaration. The Court found that only certain petitioners had standing to challenge the issuances, as their legislative powers had been impaired. The other petitioners lacked standing and failed to show any actual or threatened injury. The Court also ruled that the President's calling out power did not require a formal declaration of a state of rebellion.

ISSUES:

  1. By what authority of the Constitution or statute did the President have to send troops without the request of the Governor of the State?

  2. Whether the government has the authority to intervene in controversies that affect the public and involve matters entrusted to the care of the Nation.

  3. Whether the President has residual powers beyond those expressly enumerated in the Constitution.

  4. Whether the declaration of a state of rebellion by the President is within her powers as chief executive and commander-in-chief.

  5. Whether the declaration of a state of rebellion diminishes or violates constitutionally protected rights.

  6. Whether the declaration of a state of rebellion can lead to warrantless arrests.

RULING:

  1. The Supreme Court upheld the contempt conviction, ruling that it is within the President's authority to send troops without the request of the Governor of the State.

  2. The Supreme Court held that when the wrongs complained of affect the public at large and concern matters entrusted to the care of the Nation, the government, even if it has no pecuniary interest in the controversy, has the duty to fully discharge its constitutional duties by taking measures in the case.

  3. The Court upheld the President's residual powers, which are necessary for the President to comply with her duties under the Constitution. These powers are not limited to what is expressly enumerated in the Constitution but are implied from the grant of executive power.

  4. The declaration of a state of rebellion by the President is within her powers as chief executive and commander-in-chief.

  5. The declaration of a state of rebellion does not diminish or violate constitutionally protected rights.

  6. The declaration of a state of rebellion does not lead to warrantless arrests automatically, but warrantless arrests may be conducted if the circumstances warrant it.

PRINCIPLES:

  • The President, as Commander-in-Chief, has the power to call out the armed forces to prevent or suppress lawless violence, invasion, or rebellion, without the need for a declaration of a state of rebellion.

  • The President's executive powers, vested in him by the Constitution, give him the authority to ensure that the laws are faithfully executed, and this includes the power to address lawless violence, invasion, or rebellion.

  • A state of martial law does not suspend the operation of the Constitution, nor supplant the functioning of the civil courts or legislative assemblies, nor authorize the conferment of jurisdiction on military courts and agencies over civilians where civil courts are able to function, nor automatically suspend the privilege of the writ.

  • The suspension of the privilege of the writ shall apply only to persons judicially charged for rebellion or offenses inherent in or directly connected with invasion.

  • During the suspension of the privilege of the writ, any person arrested or detained shall be judicially charged within three days, otherwise he shall be released.

  • The President has the power to call out armed forces and suspend the privilege of the writ of habeas corpus without prior legislative approval, in case of invasion, insurrection, or rebellion.

  • The President's power as Commander-in-Chief includes the authority to employ the war power in defense of the government.

  • The President's duty is to represent and protect the people and he has independent power under his oath to fulfill this duty.

  • Congress may validate the President's use of executive power, but the President may still exercise certain powers without Congressional approval.

  • The government has the authority to intervene in controversies that affect the public and involve matters entrusted to the care of the Nation.

  • The President has residual powers that are necessary for them to comply with their duties under the Constitution.

  • The powers of the President as Chief Executive are plenary and not limited to specific provisions of the Constitution.

  • The President's authority to declare a state of rebellion is derived from her powers as chief executive and commander-in-chief.

  • The declaration of a state of rebellion is primarily intended to give notice that such a state exists and that the armed forces may be called to prevent or suppress it, but it is devoid of any legal significance.

  • The declaration of a state of rebellion does not suspend the operation of the Constitution or automatically suspend the privilege of the writ of habeas corpus.

  • A person may be subjected to a warrantless arrest for the crime of rebellion whether or not the President has declared a state of rebellion, as long as the requisites for a valid warrantless arrest are present.

  • The President has full discretionary power to call out the armed forces and determine the necessity for its exercise, as long as it is within constitutional limits and does not constitute grave abuse of discretion.

  • The declaration of a state of rebellion does not amount to a declaration of martial law or an indirect exercise of emergency powers.

  • The exercise of executive powers by the President in declaring a state of rebellion and calling out the armed forces is different from the delegated legislative powers contemplated in granting emergency powers.