G.R. No. 243522 , February 19, 2019. SENATE OF THE PHILIPPINES, ET AL., respondents.
FACTS

These consolidated petitions challenged the constitutionality of Joint Resolution No. 6, dated December 12, 2018, wherein Congress extended the proclamation of martial law and the suspension of the privilege of the writ of habeas corpus in the whole of Mindanao for one year, from January 1 to December 31, 2019. The extension was requested by President Rodrigo Roa Duterte, who cited a joint security report from the AFP and PNP. The report highlighted accomplishments under martial law, such as the neutralization of terrorist group members and a reduction in atrocities, but also asserted that rebellion persisted. It cited ongoing activities of groups like the Abu Sayyaf Group, Bangsamoro Islamic Freedom Fighters, and Daulah Islamiyah, including specific bombing incidents, as proof that public safety required the continuation of martial law.
The petitioners argued that the factual basis for the extension was insufficient. They contended that the government’s own declaration of Marawi City’s liberation in October 2017 signified the cessation of the primary rebellion that initially justified Proclamation No. 216. The petitions invoked the Supreme Court’s constitutional power of review under Section 18, Article VII, to examine whether the factual basis for Congress’s extension was sufficient and not arbitrarily established.

ISSUE

Whether Congress acted with grave abuse of discretion in finding sufficient factual basis to extend the proclamation of martial law and the suspension of the privilege of the writ of habeas corpus in Mindanao for the period of January 1 to December 31, 2019.

RULING

The Court, in its Decision, dismissed the petitions and upheld the validity of Joint Resolution No. 6. The majority ruled that Congress did not commit grave abuse of discretion in its determination. The legal logic centered on the standard of judicial review for such congressional actions. The Court reiterated that its power of review is limited to determining whether the exercise of discretion by Congress was attended by grave abuse. It is not a review of the wisdom of the decision but of its constitutional and factual basis.
The majority found that Congress based its decision on the President’s detailed report, which contained specific facts and data from security forces indicating continued rebellion and persistent threats from various terrorist groups in Mindanao. The Court held that these facts, including enumerated violent incidents and ongoing recruitment activities, provided a sufficient factual anchor for Congress to conclude that rebellion persisted and public safety required the extension. The declaration of Marawi’s liberation was deemed not to preclude the existence of a continuing rebellion elsewhere in Mindanao. The Court deferred to the collective wisdom of Congress, as the constitutional body directly entrusted with the power to extend martial law, finding no clear showing that its decision was bereft of factual support or constituted a capricious and whimsical exercise of judgment.