WRIT OF HABEAS CORPUS

LANSANG VS GARCIA
Case Digest (G.R. No. L-33964, L-33965, L-33973, L-33982, L-34004, L-34013, L-34039, L-34265, L-34339)v0.1-
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Facts:
 Multiple petitions for writs of habeas corpus were filed by individuals who were arrested and detained without
a warrant during the period of martial law in the Philippines.
 The petitioners challenged the validity of the suspension of the privilege of the writ of habeas corpus, arguing
that there was no actual rebellion or imminent danger thereof to justify such suspension.
 The President issued Proclamation No. 889 on August 30, 1971, stating that lawless elements in the country
were engaged in an armed insurrection and rebellion to forcibly seize political power and overthrow the
government.
 The proclamation suspended the privilege of the writ for persons detained for crimes of insurrection or
rebellion.
 The President later issued amendments to the proclamation, specifying the areas where the suspension of the
privilege would apply.
 The petitioners are members of various activist organizations and were detained for their involvement in
violent demonstrations and armed encounters with the government.
Issue:
 Whether the suspension of the privilege of the writ of habeas corpus was valid.
Ruling:
 The Supreme Court upheld the validity of the suspension of the privilege of the writ of habeas corpus during
martial law.
 The court ordered the release of some of the petitioners who were found to have insufficient evidence against
them, while directing a preliminary investigation for those still detained.
Ratio:
 The President had the authority to suspend the privilege of the writ under certain conditions, including the
existence of a rebellion or imminent danger thereof.
 The court has the authority to inquire into the existence of the factual bases for the suspension in order to
determine its constitutional sufficiency.
 The power to suspend the privilege of the writ of habeas corpus is not absolute or unqualified, and it is
circumscribed by certain conditions and limitations.
 The existence of a rebellion or insurrection could justify a limited withdrawal of the guarantee of individual
liberty, but mere dissent should not be mistaken for rebellion or insurrection.
 The suspension of the privilege of the writ applied to persons detained for crimes of insurrection or rebellion,
as specified in the proclamation and its amendments.
 The court emphasized the principle of separation of powers and the system of checks and balances.
 The court recognized the importance of protecting public safety and national security, but also emphasized the
role of the judiciary in safeguarding individual rights and determining the existence of probable cause.
 The right to bail is not affected by the suspension of the privilege of the writ.
DR AURORA PARONG ET AL VS PONCE ENRILE
Facts:
WRIT OF HABEAS CORPUS
The case involves a group of detainees who were arrested for subversive activities.
The detainees include Dr. Aurora Parong, Benjamin Pineda, Sabino Padilla, Francisco Divinagracia, Zenaida Mallari,
Letty Ballogan, Norberto Portuguese, Mariano Soriano, Tito Tanguilig, Imelda de los Santos, Eufronio Ortiz Jr.,
Juanito Granada, and Bienvenido Garcia.
They were arrested on different dates in July 1982.
The detainees were being held based on a Presidential Commitment Order (PCO) issued on July 12, 1982.
The PCO suspended the privilege of the writ of habeas corpus and the right to bail.
The detainees argued that their detention was illegal and sought their release through the writ of habeas corpus.
Issue:
Is the detention of the detainees valid and legal based on the PCO and the suspension of the privilege of the writ of
habeas corpus?
Ruling:
The detention of the detainees is valid and legal based on the PCO and the suspension of the privilege of the writ of
habeas corpus.
Ratio:
The PCO was issued by the President as Commander-in-Chief, and its exercise was not subject to judicial inquiry.
With the suspension of the privilege of the writ of habeas corpus, the right to bail was likewise suspended.
The continued detention of the petitioners was rendered valid and legal.
The release of the detainees would depend on the discretion of the President.
Additional Information:
The court dismissed the petition for the issuance of the writ of habeas corpus.
The court upheld the validity of the detainees' detention based on the PCO.

LAGMAN VS PIMENTEL
Facts:
This case involves consolidated petitions challenging the constitutionality of the extension of the proclamation of
martial law and suspension of the privilege of the writ of habeas corpus in the entire Mindanao for one year from
January 1 to December 31, 2018. On May 23, 2017, President Rodrigo Duterte issued Proclamation No. 216,
declaring a state of martial law and suspending the privilege of the writ of habeas corpus in the whole of Mindanao for
a period not exceeding sixty days. The President submitted a written report to the Senate and the House of
Representatives, citing the events and reasons that led to the proclamation. The Congress expressed full support for the
proclamation and found no cause to revoke it. Several petitions were subsequently filed challenging the sufficiency of
the factual basis of the proclamation, but the Court found it constitutional. On July 18, 2017, the President requested
the Congress to extend the effectivity of the proclamation, and the Congress adopted a resolution extending it until
December 31, 2017. The President then requested another extension for one year, from January 1, 2018 to December
31, 2018, citing the need to quell the rebellion and ensure public safety. The Congress granted the extension.
Issue:
The main issue raised in the case is whether there is a sufficient factual basis for the extension of martial law and
suspension of the privilege of the writ of habeas corpus in Mindanao.
Ruling:
WRIT OF HABEAS CORPUS
The Court ruled that there is a sufficient factual basis for the extension of martial law in Mindanao.
Ratio:
The Court held that there is an ongoing rebellion in the Philippines, with various armed groups engaging in armed
conflict with government forces and seeking to topple the government. The Court emphasized that the state of martial
law is an extraordinary power that is premised on necessity and meant to protect the Republic from its enemies. It also
noted that the President has the discretion to determine the existence of rebellion and the necessity of martial law, and
that the Court should defer to the President's judgment in this regard. The Court further held that the Congress, as the
representative of the people, has the authority to extend martial law if it finds that the rebellion persists and public
safety requires it. The Court found that the Congress had sufficient factual basis to grant the extension, as it relied on
the President's report and the information available to it. The Court also rejected the argument that the extension
violates the constitutional limits on the duration of martial law, as the Constitution allows Congress to extend martial
law beyond 60 days. Finally, the Court held that the suspension of the privilege of the writ of habeas corpus is justified
as it is necessary to effectively address the rebellion and ensure public safety.

LAGMAN VS MEDIALDEA
Facts:
 Petitioners in G.R. No. 231658: Representatives Edcel C. Lagman, Tomasito S. Villarin, Gary C. Alejano,
Emmanuel A. Billones, and Teddy Brawner Baguilat, Jr.
 Petitioners in G.R. No. 231771: Eufemia Campos Cullamat, Virgilio T. Lincuna, Ateliana U. Hijos, Roland A.
Cobrado, Carl Anthony D. Olalo, Roy Jim Balanghig, Renato Reyes, Jr., Cristina E. Palabay, Amaryllis H.
Enriquez, Antonio L. Tinio, Arlene D. Brosas, Sarah Jane I. Elago, Mae Paner, Gabriela Krista Dalena, Anna
Isabelle Estein, Mark Vincent D. Lim, Vencer Mari Crisostomo, and Jovita Montes.
 Petitioners in G.R. No. 231774: Norkaya S. Mohamad, Sittie Nur Dyhanna S. Mohamad, Noraisah S. Sani,
and Zahria P. Muti-Mapandi.
 On May 23, 2017, President Rodrigo Duterte issued Proclamation No. 216, declaring martial law in Mindanao
for a period not exceeding 60 days.
 The proclamation was based on the existence of rebellion and lawless violence in the region, particularly in
Marawi City, where the Maute Group and other rebel groups were causing havoc and attempting to establish
an Islamic State.
 The President cited the need to restore peace and order and protect the Filipino people from the threat of
terrorism.
Issue:
1. Whether or not the petitions are the "appropriate proceeding" covered by paragraph 3, Section 18, Article VII
of the 1987 Constitution.
2. Whether or not the power of the Court to review the sufficiency of the factual basis of the proclamation of
martial law or the suspension of the privilege of the writ of habeas corpus extends to the calibration of the
President's decision of which among his graduated powers he will avail of in a given situation.
3. Whether or not the exercise of the power of judicial review by the Court involves the calibration of graduated
powers granted the President as Commander-in-Chief, namely calling out powers, suspension of the privilege
of the writ of habeas corpus, and declaration of martial law.
4. Whether or not there were sufficient factual basis for the proclamation of martial law in Mindanao.
Ruling:
 The Supreme Court ruled in favor of upholding the constitutionality of Proclamation No. 216, declaring
martial law in Mindanao.
 The Court held that there is sufficient factual basis and compliance with constitutional requirements for the
declaration of martial law.
 The Court also clarified that its power of judicial review does not extend to the calibration of the President's
decision on which graduated power to avail of in a given situation.
Ratio:
 The power of judicial review under Section 18, Article VII of the Constitution is a special and specific jurisdiction of the
Supreme Court, different from those enumerated in Sections 1 and 5 of Article VIII.
 The Court has the authority to review the sufficiency of the factual basis of the proclamation of martial law or the
suspension of the privilege of the writ of habeas corpus in an appropriate proceeding filed by any citizen.
WRIT OF HABEAS CORPUS
 The purpose of this provision is to provide additional safeguards against possible abuse by the President in the exercise
of his emergency powers.
 The Court clarified that its power of review is independent from the power of revocation by Congress.
 While Congress has the power to revoke the proclamation or suspension, the Court's review power is not dependent on
the actions taken by Congress.
 The Court may strike down the proclamation or suspension if it finds that there is a lack of sufficient factual basis.
 The Court's power of review does not extend to the calibration of the President's decision on which graduated power to
avail of in a given situation.
 The President has the discretion to choose which extraordinary power to use, guided by the information and data
available to him at the time of the decision.
 The Court's review is limited to the sufficiency of the factual basis and does not involve questioning the President's
decision-making process.
 In this case, the Court found that there is sufficient factual basis for the proclamation of martial law in Mindanao.

PADILLA VS CONGESS
Case Digest (G.R. No. 231671 & 231694)
Facts:
 The case involves the interpretation of Article VII, Section 18 of the Philippine Constitution.
 The court reviews the history of the text and corresponding jurisprudence.
 The exercise of the power to suspend the privilege of the writ of habeas corpus was conditioned upon the
concurrence of the legislature.
 The Philippine Autonomy Act of 1916 retained the concept of habeas corpus but allowed the Governor
General to suspend the writ without legislative concurrence.
 The Tydings-Mcduffie Act or the Philippine Independence Act paved the way for the enactment of Article VII,
Section 10 of the Philippine Constitution, which grants the President the power to suspend the privilege of the
writ of habeas corpus.
 The exercise of this power is not subject to review by any other branch of the government, except when
emergency powers are granted by Congress.
Issue:
 The main issue raised in the case is the interpretation of Article VII, Section 18 of the Philippine Constitution.
 The issue revolves around the power to suspend the privilege of the writ of habeas corpus and the role of
Congress in revoking or extending such suspension.
Ruling:
 The court rules that the power to suspend the privilege of the writ of habeas corpus is not exclusively vested in
the President.
 Congress plays an active role in revoking or extending the suspension.
 Congress has the authority to revoke or affirm the President's proclamation or suspension, allow their limited
effectivity to lapse, or extend the same if deemed warranted.
 Congress' scope of review is not bound or restricted by any legal standard, except when it is arbitrary or
unreasonable.
Ratio:
 The court's decision is based on the interpretation of Article VII, Section 18 of the Philippine Constitution.
 The requirement for Congress to convene automatically and deliberate and vote jointly was intended to render
any action by a deliberative body practical in light of the exigencies.
 Congress' role is important in exercising its full powers during exigent circumstances.
WRIT OF HABEAS CORPUS
 The interpretation proposed by the majority, which suggests separate deliberations in each chamber before
convening jointly, does not make sense given the time constraints and the need for a unified response.
 The court emphasizes the need to protect fundamental rights and uphold democratic values, even during times
of perceived crisis.
Conclusion:
 The court dismisses the petitions for lack of merit and upholds the discretion of Congress to convene in joint
session or deliberate separately on the President's proclamation of habeas corpus.
 The court emphasizes the importance of harmonizing the provisions of the Constitution and the need to
balance the power of the President with the checks and balances provided by Congress.
JACKSON VS MACALINO
Facts:
 American national named Raymond Michael Jackson filed a petition for habeas corpus against the
Commissioner of the Commission on Immigration and Deportation (CID), John Doe, and Jane Doe.
 Petitioner was arrested and detained at the CID based on a summary deportation order issued by the Board of
Commissioners (BOC) on December 11, 1997, and a hold departure order of the Makati Regional Trial Court
(RTC) in Criminal Case No. 98-1155.
 Trial court dismissed the petition on the ground that it was premature as there was a pending petition to lift the
summary deportation order before the BOC filed by the petitioner.
 Dissatisfied, the petitioner filed a petition for certiorari.
Issue:
1. Whether the arrest warrants issued by the Commissioner of Immigration and Deportation are valid.
2. Whether there is a final order of deportation against the petitioner.
3. Whether the petitioner's right to due process has been violated.
Ruling:
 The arrest and detention of the petitioner were legal under the Philippine Immigration Act of 1940.
 The arrest warrants issued by the Commissioner of Immigration and Deportation were valid.
 There was a final order of deportation against the petitioner.
 The petitioner's right to due process was not violated.
Ratio:
 The court held that even if the arrest of a person is illegal, supervening events may bar his release or discharge
from custody.
 The burden of proving illegal restraint rests on the petitioner, and the return of the respondent shall be
considered prima facie evidence of the cause of restraint.
 The petitioner's right to due process was not violated as he had the opportunity to file a motion for
reconsideration with the CID and offered to post a bail bond for his provisional release.
 By offering to post a bail bond, the petitioner admitted that he was under the custody of the CID and
voluntarily accepted its jurisdiction.