G.R. No. 235935 , 236061, 236145, 236155, February 6, 2018
Representatives Edcel C. Lagman, et al., Eufemia Campos Cullamat, et al., Loretta Ann P. Rosales, and Christian S. Monsod, et al., Petitioners vs. Senate President Aquilino Pimentel III, et al., Respondents

FACTS

On May 23, 2017, President Rodrigo Roa Duterte issued Proclamation No. 216, declaring martial law and suspending the privilege of the writ of habeas corpus in the entire Mindanao for a period not exceeding sixty days due to rebellion by the Maute Group, Abu Sayyaf Group, and other armed factions. The Congress, in a joint session on July 22, 2017, subsequently extended this proclamation until December 31, 2017. In December 2017, upon the President’s request citing ongoing rebellion and public safety needs, Congress adopted Resolution of Both Houses No. 4, further extending the martial law declaration for one year, from January 1 to December 31, 2018.
Multiple petitions were filed directly with the Supreme Court, challenging the constitutionality of this one-year extension. The petitioners, including members of the House of Representatives and various citizen groups, argued that the extension lacked sufficient factual basis, was disproportionate, and violated the temporal limitation inherent in martial law declarations. They contended that the situation in Mindanao did not constitute the actual rebellion required by the Constitution to justify such a prolonged extension and that Congress committed grave abuse of discretion in granting it.

ISSUE

Whether the Congress committed grave abuse of discretion in granting the one-year extension of the proclamation of martial law and suspension of the privilege of the writ of habeas corpus in Mindanao.

RULING

The Supreme Court DISMISSED the petitions and UPHELD the constitutionality of the one-year extension. The Court ruled that Congress did not commit grave abuse of discretion in its determination. The legal logic rests on the separation of powers and the political question doctrine, as tempered by the Court’s specific reviewing power under Article VII, Section 18 of the Constitution . The Court clarified that its review is limited to ascertaining whether the President’s factual basis for requesting the extension is sufficient and whether Congress’ decision to grant it was attended by grave abuse of discretion.
The Court found the factual basis sufficient. It cited intelligence reports, military assessments, and the President’s detailed written report to Congress, which detailed persistent armed hostilities, continued violence, and the rebellion’s aim to overthrow the government. The Court deferred to the collective wisdom of Congress, which held extensive deliberations and received confidential security briefings, concluding that the extension was a rational response to the exigencies of the situation. The Court emphasized that the duration of the extension is a policy decision primarily within the discretion of the political branches, provided it is grounded on the constitutional prerequisites of actual rebellion and the requirements of public safety, which were deemed present. The ruling affirmed that the constitutional safeguards, including judicial review, remain operative during martial law.