G.R. No. 243522, February 19, 2019. EDGAR R. ERICE, ET AL. VS. HON. SALVADOR C. MEDIALDEA, ET AL.
FACTS

These consolidated petitions challenged the constitutionality of Resolution of Both Houses (RBH) No. 6, which approved the third extension of Proclamation No. 216 (declaring martial law and suspending the privilege of the writ of habeas corpus in Mindanao) from January 1 to December 31, 2019. The initial proclamation was issued by President Duterte on May 23, 2017, following the Marawi siege. Congress had previously approved two extensions, which the Supreme Court upheld in Lagman v. Medialdea and Lagman v. Pimentel III, finding sufficient factual basis for the rebellion.
The request for a third extension was based on a December 2018 recommendation from the Secretary of National Defense and the heads of the AFP and PNP. They cited a shift in ISIS strategy to a global insurgency, the recognition of a Philippines-based “East Asia Wilayat,” and recent bombing incidents in Lamitan, Isulan, and General Santos City. President Duterte’s letter to Congress detailed these bombings, kidnapping incidents by the Abu Sayyaf Group, hundreds of violent incidents perpetrated by communist groups, and significant casualties among military personnel.

ISSUE

Whether there was sufficient factual basis to justify the congressional approval, via RBH No. 6, of the third extension of martial law and the suspension of the privilege of the writ of habeas corpus in Mindanao for the period of 2019.

RULING

The Supreme Court, in its Decision, DISMISSED the petitions and declared RBH No. 6 CONSTITUTIONAL. The legal logic centers on the standard of judicial review established in the Lagman cases. The Court’s role is not to conduct a de novo review or substitute its judgment for that of the President and Congress, but to determine whether the factual basis for their decision is sufficient—meaning it is not arbitrary or capricious. The factual basis need only show that rebellion persists and that public safety requires the extension.
The Court found the factual submissions for the third extension sufficient. The intelligence reports and documented violent incidents—including bombings, kidnappings, and communist-led attacks—collectively indicated that rebellion by ISIS-linked groups and communist terrorists continued in Mindanao. The nature of the threat had evolved into asymmetric warfare, not requiring conventional territorial control but persisting through sporadic, high-impact attacks aimed at overthrowing the government. Congress, in granting the extension, acted within its constitutional discretion based on this evidence. The petitioners failed to prove that the executive and legislative branches’ assessment was devoid of factual support, thereby meeting the established standard for constitutionality.