G.R. No. L-33964, L-33965, L-33973, L-33982, L-34004, L-34013, L-34039, L-34265, L-34339. December 11, 1971.
IN THE MATTER OF THE PETITION FOR HABEAS CORPUS OF TEODOSIO LANSANG, ET AL., petitioners, vs. BRIGADIER-GENERAL EDUARDO M. GARCIA, Chief, Philippine Constabulary, respondent. (Consolidated Cases).

FACTS

These consolidated petitions for habeas corpus arose from the suspension of the privilege of the writ by President Ferdinand Marcos through Proclamation No. 889 on August 21, 1971, following the Plaza Miranda bombing. The petitioners, including individuals like Teodosio Lansang, Rogelio Arienda, and Nemesio Prudente, were detained by military authorities on suspicion of involvement with the communist rebellion. They challenged the validity of their detention, arguing the suspension was unconstitutional because there was no actual invasion, insurrection, or rebellion that justified it, and that the President’s act was a political question beyond judicial review.
The respondents, represented by the Solicitor General, maintained that the President’s determination of the existence of a rebellion was conclusive and not subject to judicial scrutiny. They asserted that the suspension was a necessary exercise of executive power to address a grave threat to public safety, and that the judiciary must defer to this executive judgment, especially in matters of national security.

ISSUE

The principal issue is whether the judiciary has the power to review the factual basis of the President’s suspension of the privilege of the writ of habeas corpus, and if so, whether such suspension was constitutional under the circumstances.

RULING

The Supreme Court, through Chief Justice Concepcion, ruled that the judiciary possesses the authority of judicial review over the President’s suspension of the privilege of the writ. The Court rejected the doctrine of political question in this context, holding that the constitutional provision (Article VII, Section 10, Paragraph 2) granting the President this power is not an unchecked political discretion but is limited by the condition that a factual situation of invasion, insurrection, rebellion, or imminent danger thereof exists, and that public safety requires the suspension. The Court’s function is to determine whether the President’s decision was within the constitutional bounds of his granted authority.
Applying this standard of review, the Court examined the evidence and found that the President did not act arbitrarily. It concluded that there was a factual basis for the proclamation, as the rebellion staged by the Communist Party of the Philippines and its military arm, the New People’s Army, posed a serious threat to public safety. The Court emphasized that its review was limited to checking for grave abuse of discretion amounting to lack or excess of jurisdiction, not to substituting its own judgment for the President’s on matters of policy. Consequently, the suspension was declared valid, and the petitions for habeas corpus were dismissed, with the Court noting that the detainees were not entirely without remedy as they could still question the legality of their specific detention before the courts.