Proclamation No. 475, ordering the temporary closure of Boracay Island for rehabilitation, is a valid exercise of the State's police power, reasonably necessary to address the environmental degradation and protect public health, safety, and the general welfare, and does not unconstitutionally impair the right to travel or the right to due process.

Boracay Island, a prime tourist destination, suffered severe environmental degradation due to factors like inadequate sewage infrastructure, improper waste disposal, illegal structures, high tourist influx, and violations of environmental laws, leading the President to describe it as a "cesspool" and necessitating government intervention for rehabilitation.

• President Duterte publicly announced plans to close Boracay Island due to severe environmental problems, calling it a "cesspool" in February 2018.
• On April 4, 2018, the President ordered the island's shutdown during a cabinet meeting, formally announced the next day for a maximum period of six months starting April 26, 2018.
• Petitioners Zabal (a sandcastle maker) and Jacosalem (a driver), residents earning income from tourism, and Bandiola (an occasional visitor), filed a Petition for Prohibition and Mandamus on April 25, 2018, fearing loss of livelihood.
• On April 26, 2018, President Duterte issued Proclamation No. 475, declaring a State of Calamity in Boracay's three barangays and ordering its temporary closure as a tourist destination from April 26 to October 25, 2018, citing environmental degradation, pollution (high fecal coliform levels), illegal structures, and inadequate waste management exacerbated by tourist influx.
• The Proclamation directed government agencies and LGUs to implement the closure and rehabilitation works, and banned tourist entry until lifted by the President.
• Petitioners filed a Supplemental Petition challenging Proclamation No. 475's constitutionality.
• Boracay was reopened to tourism on October 26, 2018, after the six-month closure period.

• Prohibition and Mandamus are proper remedies to address the constitutional issues raised regarding the President's powers and the infringement of fundamental rights.
• Proclamation No. 475 is an invalid exercise of legislative power, as the President encroached upon Congress's law-making authority by imposing restrictions (closure, travel ban) that altered the relationship between the State and the people.
• The Proclamation violates the constitutional right to travel as it lacks a specific law authorizing the restriction and fails to meet the requirements of national security, public safety, or public health.
• The Proclamation violates the right to due process by depriving petitioners and others of their right to work and earn a living in Boracay without justification, unfairly punishing the innocent for environmental violations committed by others.
• The closure cannot be justified under police power, as this power belongs to the legislature, not the executive, and the measure was unreasonable, unnecessary, and unduly oppressive.
• Proclamation No. 475 infringes upon the local autonomy of affected LGUs by ordering them to implement the closure, exceeding the President's power of supervision and amounting to control.

• President Duterte should be dropped as a respondent due to presidential immunity from suit.
• The petition is improper: prohibition is preventive and cannot restrain an act already done (fait accompli), while mandamus is inappropriate as respondents were performing, not neglecting, their duty to protect the environment.
• There is no justiciable controversy as Proclamation No. 475 does not prohibit gainful employment.
• The petition constitutes a Strategic Lawsuit Against Public Participation (SLAPP) aimed at hindering environmental law enforcement.
• Proclamation No. 475 is a valid exercise of delegated legislative power under RA 10121 (Philippine Disaster Risk Reduction and Management Act of 2010), specifically the power to declare a state of calamity upon NDRRMC recommendation.
• The Proclamation is a valid exercise of the President's executive power (Art VII, Sec 1) and power of control over the executive branch, implementing the NDRRMC recommendation.
• The President possesses residual powers necessary to address situations like Boracay's degradation, citing Marcos v. Manglapus.
• The right to travel is not absolute and can be restricted for public safety or health; existing laws already limit this right.
• The right to due process was not violated; petitioners, being in the informal sector, have no guaranteed livelihood, and private interests must yield to the State's police power for the public good.
• Proclamation No. 475 does not violate local autonomy; RA 10121 involves LGUs, but the scale of Boracay's problem necessitates national intervention, and the State retains power despite devolution.

• Whether President Duterte is immune from suit and should be dropped as a respondent.
• Whether the remedies of Prohibition and Mandamus are proper.
• Whether the requisites for judicial review are present (actual case/controversy, locus standi, earliest opportunity, lis mota).
• Whether the petition is a SLAPP.
• Whether Proclamation No. 475 constitutes an unconstitutional impairment of the right to travel.
• Whether Proclamation No. 475 constitutes an unconstitutional violation of the right to due process.
• Whether Proclamation No. 475 is a valid exercise of the President's executive power and/or police power.
• Whether Proclamation No. 475 unduly infringes upon the local autonomy of the concerned Local Government Units (LGUs).

• President Duterte was dropped as a respondent based on the doctrine of presidential immunity from suit during his tenure.
• Prohibition and Mandamus are appropriate remedies to raise constitutional issues against acts of legislative and executive officials, even if the act (closure) is already implemented, extending beyond the typical scope of Rule 65.
• All requisites for judicial review were met: an actual controversy existed despite Boracay's reopening due to potential constitutional violations and the issue being capable of repetition; petitioners' lack of direct injury (locus standi) was waived due to the transcendental importance of the constitutional issues and environmental concerns; the constitutional question was raised at the earliest opportunity; and the constitutionality of Proclamation No. 475 was the central issue (lis mota).
• The SLAPP defense was deemed inapplicable as the core issue was the constitutionality of the Proclamation, not merely an environmental case.
• Proclamation No. 475 does not impair the right to travel in its essential sense; the restriction on entry for tourists/non-residents was merely a consequence of the island's closure for rehabilitation, temporary (six months), and not aimed directly at restricting travel itself, unlike specific laws that directly regulate movement.
• Proclamation No. 475 does not violate the right to due process; petitioners, as informal workers, possess no vested property right to their income derived from tourism, which is contingent and not guaranteed. Property rights must yield to the valid exercise of police power for the general welfare. The closure was not intended as a penalty but as a necessary measure for the common good.
• Proclamation No. 475 is upheld as a valid police power measure. It serves a lawful subject (protecting environment, public health, safety, general welfare) through lawful means (temporary closure deemed reasonably necessary and not unduly oppressive given the extent of degradation and complexity of rehabilitation works). The Court found it unnecessary to rely on residual powers, anchoring the validity primarily on police power exercised pursuant to existing laws (implicitly including RA 10121 and environmental statutes).
• Proclamation No. 475 does not unduly intrude into LGU autonomy. While RA 10121 emphasizes the LGU role, Boracay's environmental crisis is a national concern requiring national agency intervention. The Proclamation itself directs coordination with and involvement of LGUs.
• The Petition for Prohibition and Mandamus was DISMISSED.

• Presidential Immunity from Suit: Definition: An incumbent President cannot be sued in any civil or criminal case during their tenure. Application: President Duterte was dropped as a respondent because suing him would degrade the dignity of the office and distract him from his duties.
• Police Power: Definition: The inherent power of the State to enact legislation interfering with personal liberty or property to promote the general welfare. Application: Proclamation No. 475 was upheld as a valid exercise of police power, aimed at protecting the environment and public health (lawful subject) through temporary closure (lawful means deemed reasonably necessary and not unduly oppressive).
• Right to Travel (Art. III, Sec. 6): Definition: The right to move freely within the Philippines or to other countries, which can only be impaired by law in the interest of national security, public safety, or public health. Application: The Court ruled the right was not directly impaired by Proclamation No. 475, as the travel restriction was merely an incidental consequence of the temporary closure for rehabilitation, not its primary purpose, and was temporary.
• Due Process (Art. III, Sec. 1): Definition: No person shall be deprived of life, liberty, or property without due process of law; requires fundamental fairness and prohibits arbitrary government action. Application: The Court held due process was not violated regarding petitioners' livelihood, as they had no vested property right to their contingent income as informal workers, and such interests must yield to police power exercised for the common good.
• Locus Standi (Legal Standing): Definition: A party's personal and substantial interest in a case, requiring direct injury from the challenged governmental act. Application: While petitioners lacked direct injury regarding lost income (no vested right), the Court waived the requirement due to the transcendental importance of the constitutional and environmental issues involved.
• Transcendental Importance: Definition: An exception to the locus standi requirement allowing suits involving issues of paramount public interest even if the plaintiff suffers no direct injury. Application: Applied to allow the petition despite petitioners' lack of direct injury, given the significant constitutional questions and the public interest in Boracay's rehabilitation and environmental protection.
• Separation of Powers: Definition: The division of governmental powers among the legislative, executive, and judicial branches. Application: Petitioners argued the President usurped legislative power, but the Court found Proclamation No. 475 was not a legislative act but an exercise of police power/executive power based on existing frameworks.
• Executive Power (Art. VII, Sec. 1 & 17): Definition: The power vested in the President to enforce and administer laws, including the power of control over executive departments and the duty to ensure faithful execution of laws. Application: Respondents argued the Proclamation was an exercise of executive power, particularly the power of control in implementing NDRRMC recommendations and coordinating rehabilitation. The Court primarily relied on police power.
• Delegated Legislative Power: Definition: Power delegated by Congress to administrative agencies or the President to 'fill in the details' of a law. Application: Respondents argued Proclamation No. 475 was based on delegated power under RA 10121 (declaration of state of calamity). The Court implicitly accepted this as part of the justification for the President's action within the police power framework.
• Local Autonomy (Art. X, Sec. 2): Definition: The principle granting territorial and political subdivisions genuine and meaningful self-governance. Application: The Court found no undue violation, reasoning that Boracay's problem was of national scope requiring national intervention, and the Proclamation involved LGUs as mandated by law (RA 10121).
• Judicial Review: Definition: The power of the courts to review the constitutionality of acts of other branches of government. Application: The Court exercised judicial review after finding all requisites (actual case, locus standi waived, earliest opportunity, lis mota) were satisfied.
• Vested Rights: Definition: Rights that are fixed, unalterable, irrevocable, and have completely accrued, protected by due process. Application: The Court found petitioners had no vested rights to their informal sector income, only an inchoate expectancy, thus their due process claim failed.

• "x x x Settled is the doctrine that the President, during his tenure of office or actual incumbency, may not be sued in any civil or criminal case x x x."
• "x x x certiorari, prohibition and mandamus are appropriate remedies to raise constitutional issues and to review and/or prohibit/nullify, when proper, acts of legislative and executive officials x x x."
• "Any bearing that Proclamation No. 475 may have on the right to travel is merely corollary to the closure of Boracay x x x necessary incidents of the island's rehabilitation. There is certainly no showing that Proclamation No. 475 deliberately meant to impair the right to travel."
• "Undoubtedly, Proclamation No. 475 is a valid police power measure. To repeat, police power constitutes an implied limitation to the Bill of Rights, and that even liberty itself, the greatest of all rights, is subject to the far more overriding demands and requirements of the greater number."
• "x x x when the conditions so demand as determined by the legislature, property rights must bow to the primacy of police power because property rights, though sheltered by due process, must yield to general welfare."
• "x x x petitioners, particularly Zabal and Jacosalem, cannot be said to have already acquired vested rights to their sources of income in Boracay. x x x they are part of the informal sector of the economy where earnings are not guaranteed."
• "All told, the Court sustains the constitutionality and validity of Proclamation No. 475."

• David v. Macapagal-Arroyo (522 Phil. 705): Cited for the doctrine of Presidential Immunity from suit. Also cited in dissent regarding scope of proclamation power.
• Tañada v. Angara (Cited in Spouses Imbong v. Ochoa): Cited to establish that certiorari, prohibition, and mandamus are proper remedies for raising constitutional issues.
• La Bugal-B'laan Tribal Association, Inc. v. Sec. Ramos (465 Phil 860): Cited for the definition of "actual case or controversy" as a requisite for judicial review.
• Galicto v. Aquino III (683 Phil 141): Cited to illustrate lack of locus standi based on speculative or contingent interest (loss of future salary increases). Distinguished by the Court regarding petitioners' situation.
• Anak Mindanao Party-List Group v. Executive Secretary Ermita (558 Phil. 338): Cited for the requirements of direct and personal injury for locus standi.
• Funa v. Chairman Villar (686 Phil. 571): Cited for the principle of waiving locus standi due to transcendental importance.
• Philippine Association of Service Exporters, Inc. v. Hon. Drilon (246 Phil. 393): Cited to show that not all regulations affecting travel impair the right to travel (deployment ban); also cited regarding the nature of police power.
• Oposa v. Hon. Factoran, Jr. (296 Phil. 694): Cited extensively for the importance of the right to a balanced and healthful ecology and the State's duty to protect it, justifying the need for urgent action in Boracay.
• Ermita-Malate Hotel & Motel Operators Association, Inc. v. The Hon. City Mayor of Manila (128 Phil. 473): Cited for the principle that police power can override private business interests for the public good and for the standard of reasonableness in due process challenges. Also cited in dissent regarding levels of scrutiny.
• Southern Luzon Drug Corporation v. Department of Social Welfare and Development (G.R. No. 199669): Cited for the definition of "vested rights" and to argue petitioners lacked them. Distinguished in dissent.
• Metropolitan Manila Development Authority v. Concerned Residents of Manila Bay (595 Phil. 305): Cited as an analogous case where the Court mandated government action for environmental rehabilitation (Manila Bay) and emphasized the need for proactive measures.
• Marcos v. Manglapus (258 Phil. 479): Cited by respondents to support the concept of presidential residual powers, though the Court did not heavily rely on this. Also cited in dissent regarding its sui generis nature.
• Genuino v. De Lima (G.R. Nos. 197930, etc.): Cited in concurrences and dissents regarding the strict requirements (explicit law) for impairing the right to travel.
• White Light Corporation v. City of Manila (596 Phil. 444): Cited in dissent regarding overbreadth/reasonableness of police power measures affecting innocent parties and levels of due process scrutiny.

• 1987 Constitution:
  • Art. II, Sec. 15 (Right to health)
  • Art. II, Sec. 16 (Right to balanced and healthful ecology)
  • Art. III, Sec. 1 (Due Process Clause - life, liberty, property)
  • Art. III, Sec. 6 (Liberty of abode and Right to Travel)
  • Art. VII, Sec. 1 (Executive Power vested in the President)
  • Art. VII, Sec. 17 (President's Power of Control; Duty of Faithful Execution)
  • Art. X, Sec. 2 (Local Autonomy)
  • Art. X, Sec. 4 (President's General Supervision over LGUs)
  • Art. XII, Sec. 2 (Protection of Marine Wealth)
• Republic Act No. 10121 (Philippine Disaster Risk Reduction and Management Act of 2010):
  • Sec. 16 (Declaration of State of Calamity)
  • Sec. 2 (Declaration of Policy - LGU role)
  • Sec. 17 (Remedial Measures during State of Calamity)
  • Sec. 3(ll) (Definition of State of Calamity)
  • Sec. 6(c) (NDRRMC power to recommend declaration)
  • Sec. 11 (LGU Organization)
  • Sec. 12 (LDRRMO)
  • Sec. 15 (Coordination during emergencies - LGU lead)
• Republic Act No. 9275 (Philippine Clean Water Act of 2004): Cited as basis for environmental standards and DENR/LGU roles in water quality management.
  • Sec. 6 (Management of Non-attainment Areas)
  • Sec. 16 (Clean-up Operations)
  • Sec. 27 (Prohibited Acts)
  • Sec. 28 (Fines, Damages, Penalties)
• Rules of Court:
  • Rule 65, Sec. 2 (Petition for Prohibition)
  • Rule 65, Sec. 3 (Petition for Mandamus)
• Rules of Procedure for Environmental Cases (A.M. No. 09-6-8-SC):
  • Rule 6 (Strategic Lawsuit Against Public Participation - SLAPP)
• Executive Order No. 292 (Administrative Code of 1987):
  • Book III, Title I, Chapter 2, Sec. 4 (Definition of Proclamations)
• Presidential Decree No. 1064 (s. 2006): Mentioned in Proc. 475 regarding land classification in Boracay.
• Civil Code: Cited in dissent regarding nuisance (Arts. 694-704).
• Presidential Decree No. 1586 (Environmental Impact Statement System): Mentioned in concurrences/dissents.
• Commonwealth Act No. 548: Cited in concurrence regarding temporary road closure power.