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REPRESENTATIVES EDCEL C. LAGMAN v. SALVADOR C. MEDIALDEA

FACTS:

On July 4, 2017, the Court rendered its Decision finding sufficient factual bases for the issuance of Proclamation No. 216 and declaring it as constitutional. Petitioners filed Motions for Reconsideration, as well as the Office of the Solicitor General (OSG) who filed their Comment. The Motions for Reconsideration raised concerns about the sufficiency of the factual bases of Proclamation No. 216 and the parameters used to determine that sufficiency. However, no substantial arguments were presented to convince the Court to reconsider its decision.

The issue of the sufficiency of the factual bases of Proclamation No. 216 became moot when it expired on July 23, 2017. The declaration of martial law and suspension of the privilege of the writ of habeas corpus by the President is effective for 60 days as provided in Section 18, Article VII of the Constitution. Any extension of the declaration and/or suspension should be determined by Congress. Proclamation No. 216 expired, and the current martial law and suspension of the writ of habeas corpus in Mindanao are based on Resolution of Both Houses No. 11 (RBH No. 11), which is different from Proclamation No. 216. The approval of the extension by Congress is a separate incident that the Court has no jurisdiction to review.

Considering the expiration of Proclamation No. 216 and the approval of the extension, the Court found no reason to disturb its finding that there were sufficient factual bases for the President's issuance of Proclamation No. 216.

Although the Motions for Reconsideration are moot, the Court emphasized its discussion on the parameters for determining the sufficiency of the factual basis for the declaration of martial law and/or the suspension of the privilege of the writ of habeas corpus. The Constitution requires sufficiency of factual basis, not accuracy. Petitioners argued that the Court is required to determine the accuracy of the factual basis, but the Court held that accuracy is not the same as sufficiency. The Court explained that expecting precision in the President's appreciation of facts would unduly burden him and impede the decision-making process. The framers of the Constitution also considered intelligence reports of military officers as credible evidence for the President's appraisal.

ISSUES:

  1. Whether the issue of sufficiency of factual bases of Proclamation No. 216 is moot due to its expiration.

  2. Whether the Court has jurisdiction to review the approval of the extension of the declaration of martial law and the suspension of the privilege of the writ of habeas corpus by Congress.

  3. Whether the Court is required to determine the accuracy of the factual basis of the President for the declaration of martial law and/or the suspension of the privilege of the writ of habeas corpus.

RULING:

  1. The issue of sufficiency of factual bases of Proclamation No. 216 is moot due to its expiration.

  2. The Court does not have jurisdiction to review the approval of the extension of the declaration of martial law and the suspension of the privilege of the writ of habeas corpus by Congress.

  3. The Court is not required to determine the accuracy of the factual basis of the President for the declaration of martial law and/or the suspension of the privilege of the writ of habeas corpus.

PRINCIPLES:

  • The initial declaration of martial law and/or suspension of the writ of habeas corpus is determined solely by the President, while the extension of the declaration and/or suspension, although initiated by the President, is approved by Congress.

  • A case becomes moot and academic when it "ceases to present a justiciable controversy by virtue of supervening events, so that a declaration thereon would be of no practical value."

  • The Constitution requires sufficiency of factual basis, not accuracy, for the declaration of martial law and/or the suspension of the privilege of the writ of habeas corpus.

  • Requiring the Court to determine the accuracy of the factual basis of the President contravenes the Constitution as Section 18, Article VII only requires the Court to determine the sufficiency of the factual basis.