Background
The case primarily revolved around the legality of arresting individuals without a court order, based solely on martial law powers. The petitioners argued that the martial law proclamation was unconstitutional, and that the arrests violated due process. The respondents maintained that the arrests were necessary for national security given the ongoing rebellion.
History
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The petitions were filed following the arrest of the petitioners under martial law declared on September 21, 1972.
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The President issued General Order No. 2, authorizing the arrest of individuals involved in conspiracy against the government.
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The Supreme Court issued writs of habeas corpus, directing respondents to produce the petitioners in Court and justify their detention.
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Separate opinions by Justices were later issued on September 12, 1974, after deliberations concluded.
Facts
- 1. The petitioners were arrested without formal charges, detained under the authority granted by Proclamation No. 1081.
- 2. Martial law was declared in response to perceived threats from communist insurgents and ongoing rebellion.
- 3. The petitioners sought their release through habeas corpus petitions, asserting their arrest and detention were unconstitutional.
Arguments of the Petitioners
- 1. The petitioners argued that their detention without charges violated their constitutional rights.
- 2. They claimed that martial law was improperly declared and did not justify the deprivation of liberty without due process.
- 3. Jose W. Diokno argued that the imposition of martial law was unconstitutional under the 1935 Constitution.
Arguments of the Respondents
- 1. The respondents argued that martial law was constitutionally declared under the President’s powers as Commander-in-Chief.
- 2. The detention was deemed necessary for maintaining public order and national security amid the rebellion and insurrection.
Issues
- 1. Whether the declaration of martial law by President Marcos was constitutionally valid.
- 2. Whether the arrests and detentions made under the proclamation were justified and in accordance with the law.
- 3. Whether the judiciary could inquire into the factual basis of martial law.
Ruling
- 1. The Supreme Court ruled that the proclamation of martial law and the arrests were within the powers granted to the President by the 1935 Constitution. It was held that the President's determination of the necessity for martial law was final and conclusive on the judiciary. As such, the petitions for habeas corpus were dismissed.
Doctrines
- 1. Political Question Doctrine: Several Justices opined that the determination of conditions requiring martial law was a political question, not subject to judicial review.
- 2. Commander-in-Chief Powers: Under Article VII, Section 10(2) of the 1935 Constitution, the President had the authority to proclaim martial law during periods of insurrection or rebellion.
Key Excerpts
- 1. "The present state of martial law in the Philippines is peculiarly Filipino and fits into no traditional patterns or judicial precedents."
- 2. "The preservation of society and national survival take precedence."
Precedents Cited
- 1. Lansang v. Garcia (1971): This case was cited to discuss the standards for judicial inquiry into executive actions like the suspension of the writ of habeas corpus. In Aquino v. Enrile, the Court emphasized that while it could inquire into whether the President acted arbitrarily, the President's discretion remained paramount.
Statutory and Constitutional Provisions
- 1. 1935 Constitution, Article VII, Section 10(2): This provision authorized the President to declare martial law in cases of invasion, insurrection, or rebellion, or when public safety requires it.
- 2. Bill of Rights: The petitioners argued violations under the due process provisions and right against unreasonable detention.