Title
Lagman vs. Pimentel III
Case Decision Date
G.R. No. 235935 Feb 6, 2018
The Court upholds the constitutionality of the extension of martial law in Mindanao,
citing an ongoing rebellion and the President's discretion, while emphasizing the
Congress' authority to extend martial law if public safety requires it.
Case Digest (G.R. No. 235935, 236061, 236145, 236155)
Comprehensive
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 Mindanao due
to the rebellion by the Maute Group and other rebel factions.
The initial proclamation was for 60 days, and Congress supported it after the
President's report.
The Supreme Court upheld the proclamation's constitutionality in Lagman v.
Medialdea.
On July 22, 2017, Congress extended martial law until December 31, 2017.
Despite the liberation of Marawi City on October 17, 2017, the President requested
another extension on December 8, 2017, citing ongoing threats from various rebel
groups.
Congress, in a joint session on December 13, 2017, adopted Resolution of Both Houses
No. 4, extending martial law in Mindanao for another year, from January 1 to December
31, 2018.
Several petitioners challenged this decision, leading to consolidated cases before the
Supreme Court.
Issue:
1. Does the persistence of rebellion in Mindanao justify the extension of martial law and
the suspension of the privilege of the writ of habeas corpus?
2. Does public safety require the extension of martial law in Mindanao?
3. Is the inclusion of the New People's Army (NPA) rebellion as a basis for the extension
valid?
4. Is the one-year period of extension reasonable and justified?
Ruling:
1. The Supreme Court ruled that there is sufficient factual basis for the extension of
martial law in Mindanao, as the rebellion persists.
2. The Court found that public safety requires the extension of martial law in Mindanao.
3. The inclusion of the NPA rebellion as a basis for the extension is valid.
4. The one-year period of extension is reasonable and justified.
Ratio:
The Court emphasized that the persistence of rebellion by various groups, including
the Maute Group, the Bangsamoro Islamic Freedom Fighters (BIFF), and the Abu
Sayyaf Group (ASG), justifies the extension of martial law.
The Court noted that these groups continue to recruit, train, and plan attacks, posing a
significant threat to public safety.
The inclusion of the NPA rebellion was deemed valid as it intensified its activities,
contributing to the overall threat in Mindanao.
The Court found the one-year extension reasonable, given the complexity and scale of
the threats, and the need for a comprehensive approach to ensure public safety and
order.
The Court underscored the importance of the President's discretion and Congress'
authority in determining the necessity and duration of martial law, provided there is
sufficient factual basis and adherence to constitutional safeguards.
Additional Facts:
The case involves the extension of martial law in Mindanao, Philippines, initiated by
President Rodrigo Duterte.
On December 8, 2017, President Duterte requested Congress to extend martial law and
the suspension of the privilege of the writ of habeas corpus in Mindanao for one year,
from January 1, 2018, to December 31, 2018.
This request was based on letters from AFP Chief of Staff General Rey Leonardo B.
Guerrero and Secretary of National Defense Delfin N. Lorenzana, citing ongoing threats
from various terrorist groups, including remnants of the Maute Group, the
Bangsamoro Islamic Freedom Fighters (BIFF), and the Abu Sayyaf Group (ASG).
The President's letter highlighted the continued recruitment and training activities of
these groups, their financial and logistical build-up, and their plans for future attacks.
Congress, after a joint session and extensive debate, approved the extension through
Resolution of Both Houses No. 4 on December 13, 2017.
The petitioners challenged the extension, arguing that there was no sufficient factual
basis for it and that the extension violated constitutional limits on the duration of
martial law.
Additional Issue:
1. Is there sufficient factual basis for the one-year extension of martial law and the
suspension of the privilege of the writ of habeas corpus in Mindanao?
2. Did Congress act within its constitutional authority in extending martial law for one
year?
3. Does the extension of martial law violate the constitutional mandate of a limited
duration for such declarations?
Additional Ruling:
The Supreme Court ruled that there was sufficient factual basis for the extension of
martial law in Mindanao.
The Court found that the threats from various terrorist groups, including the Maute
Group, BIFF, and ASG, justified the extension.
The Court held that Congress acted within its constitutional authority in extending
martial law for one year.
The Court determined that the extension did not violate the constitutional mandate of a
limited duration for martial law declarations.
Additional Ratio:
The Court's decision was based on the evidence presented by the President and the
AFP, which showed that the remnants of terrorist groups continued to pose a
significant threat to public safety in Mindanao.
The Court noted that the recruitment and training activities of these groups, their
financial and logistical build-up, and their plans for future attacks justified the
extension of martial law.
The Court emphasized that the Constitution grants Congress the authority to
determine the period of extension for martial law, and that Congress had acted within
this authority in approving the one-year extension.
The Court further held that the extension did not violate the constitutional mandate of a
limited duration for martial law declarations, as the Constitution allows for extensions
if the conditions for martial law persist.
