Case Digest: Lagman vs Medialdea

 Lagman vs Medialdea 

ISSUE:  Whether or not there is a sufficient factual basis for the proclamation of martial law or the suspension of the privelege of writ of habeas corpus 

FACTS:  On May 23, 2017, President Rodrigo Duterte issued Proclamation No. 216, declaring Martial Law in the whole island of Mindanao and the suspension of the privilege of the writ of habeas corpus therein. On May 25, the president submitted a written report to Congress on the factual basis of the Martial Law declaration (as required by the Constitution).  The main basis of the declaration was the attack of the Maute terrorist group in Marawi City. According to the report, the Maute group is an affiliate of ISIS which is aiming to establish an Islamic caliphate in Marawi City (and might spread its control in all the other parts of Mindanao). It also cited the ongoing rebellion and lawless violence that has plagued Mindanao for decades. 
DECISION:  Yes 
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RATIO DECIDENDI:  In reviewing the sufficiency of the factual basis of the proclamation or suspension, the Court considers only the information and data available to the President prior to or at the time of the declaration.    The determination by the Court of the sufficiency of factual basis must be limited only to the facts and information mentioned in the Report and Proclamation.    The Court held that the President, in issuing Proclamation No. 216, had sufficient factual bases tending to show that actual rebellion exists. The President only has to ascertain if there is probable cause for a declaration of Martial Law and the suspension of the writ of habeas corpus.    The petitioners’ counter-evidence were derived solely from unverified news articles on the internet, with neither the authors nor the sources shown to have affirmed the contents thereof.    As the Court has consistently ruled, news articles are hearsay evidence, twice removed, and are thus without any probative value, unless offered for a purpose other than proving the truth of the matter asserted.    The alleged false and/or inaccurate statements are just pieces and parcels of the Report; along with these alleged false data is an arsenal of other independent facts showing that more likely than not, actual rebellion exists.  
​ISSUE:  Whether or not there is a sufficient factual basis for the proclamation of martial law or the suspension of the privelege of writ of habeas corpus 

FACTS:  On May 23, 2017, President Rodrigo Duterte issued Proclamation No. 216, declaring Martial Law in the whole island of Mindanao and the suspension of the privilege of the writ of habeas corpus therein. On May 25, the president submitted a written report to Congress on the factual basis of the Martial Law declaration (as required by the Constitution).  The main basis of the declaration was the attack of the Maute terrorist group in Marawi City. According to the report, the Maute group is an affiliate of ISIS which is aiming to establish an Islamic caliphate in Marawi City (and might spread its control in all the other parts of Mindanao). It also cited the ongoing rebellion and lawless violence that has plagued Mindanao for decades. 

DECISION:  Yes 

RATIO DECIDENDI:  In reviewing the sufficiency of the factual basis of the proclamation or suspension, the Court considers only the information and data available to the President prior to or at the time of the declaration.    The determination by the Court of the sufficiency of factual basis must be limited only to the facts and information mentioned in the Report and Proclamation.    The Court held that the President, in issuing Proclamation No. 216, had sufficient factual bases tending to show that actual rebellion exists. The President only has to ascertain if there is probable cause for a declaration of Martial Law and the suspension of the writ of habeas corpus.    The petitioners’ counter-evidence were derived solely from unverified news articles on the internet, with neither the authors nor the sources shown to have affirmed the contents thereof.    As the Court has consistently ruled, news articles are hearsay evidence, twice removed, and are thus without any probative value, unless offered for a purpose other than proving the truth of the matter asserted.    The alleged false and/or inaccurate statements are just pieces and parcels of the Report; along with these alleged false data is an arsenal of other independent facts showing that more likely than not, actual rebellion exists.