G.R. No. L-35546, L-35538, L-35539, L-35540, L-35547, L-35556, L-35567, L-35571, L-35573. September 17, 1974.
IN THE MATTER OF THE PETITION FOR HABEAS CORPUS OF BENIGNO S. AQUINO, JR., ET AL., petitioners, vs. HON. JUAN PONCE ENRILE, SECRETARY OF NATIONAL DEFENSE, ET AL., respondents.

FACTS

These consolidated petitions for habeas corpus were filed by various individuals, including prominent opposition figures and journalists like Benigno Aquino Jr. and Jose Diokno, who were arrested and detained following the declaration of martial law through Proclamation No. 1081 dated September 21, 1972. The petitioners challenged the legality of their detention, arguing it violated their constitutional rights. During the pendency of the cases, significant developments occurred: several petitioners were released from custody, others were allowed to withdraw their petitions, and Jose Diokno was released by presidential order on September 11, 1974, after having previously filed a motion to withdraw his petition.
The Court faced unique procedural circumstances, leading to the issuance of multiple separate opinions rather than a single consolidated decision. This was due to profound disagreements among the Justices on whether to address broader constitutional issues surrounding martial law or to limit rulings to the specific, often mooted, petitions. The Court also grappled with the procedural question of whether to grant Diokno’s motion to withdraw his petition while he remained detained, with an initial vote showing a division (7-6 in favor of granting the motion).

ISSUE

The primary legal issue was whether the petitions for habeas corpus should be granted, compelling the respondents to justify the legality of the petitioners’ detention under martial law. A collateral procedural issue was the proper disposition of the petitions that had become moot due to the petitioners’ release or withdrawal.

RULING

The Supreme Court En Banc dismissed all petitions. The per curiam decision noted that a consensus for a single opinion was impossible due to deep divisions on the philosophical and constitutional treatment of martial law, with Justices authoring separate concurring, dissenting, and qualifying opinions. The legal logic for dismissal rested primarily on the doctrine of mootness. The Court found that for the majority of petitioners, the cases had been rendered moot and academic. Many had been released from detention, albeit sometimes with restrictions, while others had voluntarily withdrawn their petitions with the Court’s approval. The petition of Jose Diokno was dismissed specifically for being moot following his release.
Regarding the sole remaining active petitioner of significance, Benigno Aquino Jr., the Court effectively sustained the validity of his detention by dismissing his petition. The separate opinions reveal the fractured legal reasoning: a majority of Justices, directly or implicitly, recognized the validity of Proclamation No. 1081 and the suspension of the privilege of the writ of habeas corpus, thereby deferring to the executive’s authority during the martial law period. The dismissal of Aquino’s petition, despite formal charges being filed against him, signified the Court’s unwillingness at that time to question the factual basis of martial law declarations or the President’s determination of a state of rebellion. Thus, the collective outcome affirmed the government’s authority to detain individuals under martial law, marking a pivotal judicial moment of acquiescence to the Marcos regime.