LAGMAN vs.

MEDIALDEA
July 4, 2017 DEL CASTILLO, J

FACTS
 Pres. Duterte issued Proclamation No. 216 declaring Martial Law and suspending the writ of
habeas corpus for 60 days in the whole of Mindanao (May 23, 2017) He submitted 2 days after the
factual report, detailing the attacks in Mindanao for the past decades, on the basis for this
proclamation.
 He proclaimed Martial Law because of the siege of Marawi by the Maute group, highlighting the
crucial and significant role the location of Marawi plays in Mindanao, pointing out all possible
repercussions if Marawi falls under the control of these groups.
 Senate and House of Representatives both declared full support for this declaration of Martial
Law.

LAGMAN PETITION:
(1) Declaration of Martial Law has no sufficient factual basis because there is no rebellion/invasion in
Marawi or any part of Mindanao.
(2) Has no sufficient factual basis because the Pres.’s report contained “false, inaccurate, hyperbolic
accounts”
(3) No sufficient factual basis because of the inclusion of events in the Report which had long been
resolved
(4) No sufficient factual basis because the president acted alone without consulting military
establishment or ranking official
(5) No sufficient factual basis because it was shown that military was able to pre-empt Maute group in
their plan to take over Marawi
CULLAMAT PETITION:
 Seeks nullification of Proclamation 216 for being unconstitutional; lacks sufficient factual basis
that there is rebellion in Mindanao and that public safety warrants its declaration
MOHAMAD PETITION:
 Claims that Martial Law is a last resort solution and should be resorted to only after the exhaustion
of other remedies

ISSUE/S:
 W/N calling out power of the president was validly exercised -YES
 W/N there is sufficient factual basis and the requirements for public safety were sufficient for the
declaration of Martial Law - YES
 W/N there is sufficient factual basis and requirements for public safety were sufficient for the
declaration for the suspension of the privilege of writ of habeas corpus. - YES

HOLDING:
Declaration of Proclamation 216 is CONSTITUTIONAL

RATIO:
 Prior to proclamation of Martial Law, Pres. already declared state of National Emergency on
account of lawless violence in Mindanao. Both Congress and Court do not have power to interfere
with the decision-making power of the president; they cannot dictate which of the three
extraordinary powers to resort to when dealing with a crisis.
 The President’s conclusion that there was an armed public uprising, the culpable purpose of which
was removal from allegiance of the PH Gov’t a portion of its territory, and deprivation of the
president from performing his powers and prerogatives, satisfies Sec. 18, Art. 7, which dictates
sufficiency of factual basis for declaration of Martial Law.
 Consti grants to the Pres. the discretion to determine the territorial coverage or application of
martial law and the suspension of the privilege of writ of habeas corpus.