Primary Holding

The Supreme Court ruled that President Corazon C. Aquino had the authority to bar the Marcos family from returning to the Philippines, citing the broader residual powers of the President to act in the interest of national welfare, security, and public safety.

Background

After being ousted in the 1986 EDSA People Power Revolution, Ferdinand Marcos and his family went into exile in Hawaii. In 1989, Marcos, who was gravely ill, sought to return to the Philippines to die in his homeland. President Aquino denied his request, citing potential threats to national security and public safety. Marcos’s family and the Philippine Constitution Association filed a petition challenging the decision.

Facts

• 1. Marcos was ousted by the People Power Revolution and went into exile in Hawaii.
• 2. His administration left the Philippines politically and economically unstable.
• 3. In 1989, Marcos expressed his desire to return to the country primarily for health reasons.
• 4. President Aquino barred his return, citing the risks of destabilization and threats to national security.

Arguments of the Petitioners

• 1. The Marcos family argued that their right to return to the Philippines was protected under the Constitution.
• 2. They emphasized the liberty of abode (Section 6 of the Bill of Rights) and the right to travel.
• 3. They also cited international law provisions like the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, which guarantee the right of individuals to return to their own country.

Arguments of the Respondents

• 1. The government contended that Marcos's return presented a clear and present danger to national security and public safety.
• 2. The President’s action was deemed a political question, falling under her broad discretionary powers as Chief Executive.
• 3. Respondents also highlighted the government’s obligation to protect and promote the general welfare, citing Article II, Sections 4 and 5 of the 1987 Constitution.

Issues

• 1. Does President Aquino have the power to prohibit the Marcoses from returning to the Philippines?
• 2. If so, did the President act with grave abuse of discretion in barring their return?

Ruling

• 1. The President’s residual powers allow her to act in cases not explicitly covered by the Constitution, as long as such actions align with her duty to protect public welfare.
• 2. The Supreme Court found that factual bases existed for the President’s determination that Marcos’s return posed a threat to national security and public safety.
• 3. It was held that this was not a grave abuse of discretion.

Doctrines

• 1. Residual Presidential Powers: The President may exercise powers not specifically enumerated in the Constitution if such powers are necessary to uphold national welfare and public safety.
• 2. Supremacy of National Security: Individual rights may be curtailed to protect the broader interests of the State.

Key Excerpts

• 1. "The President’s residual powers are implicit in and correlative to the paramount duty residing in that office to safeguard and protect general welfare."
• 2. "The people surrendered their sovereignty to the State for the common good."

Precedents Cited

• 1. Lansang v. Garcia: Established the judiciary's authority to review executive decisions under the "grave abuse of discretion" standard.
• 2. Zaldivar v. Sandiganbayan: Addressed limits to constitutional rights when national interest is at stake.

Statutory and Constitutional Provisions

• 1. 1987 Constitution, Article III, Section 6: Guarantees liberty of abode and the right to travel, except in the interests of national security, public safety, or public health, as provided by law.
• 2. Universal Declaration of Human Rights, Article 13(2): Provides for the right to return to one’s country.
• 3. International Covenant on Civil and Political Rights, Article 12(4): Protects against arbitrary deprivation of the right to enter one’s country.