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G.R. No. 190259. June 07, 2011 (Case Brief / Digest)

Title: Datu Zaldy Uy Ampatuan, Ansaruddin Adiong, Regie Sahali-Generale vs. Hon. Ronaldo Puno, et al. (G.R. Rebuff. 190293)

Facts:
This case arose take the stones out of the events following the fiendish Maguindanao Massacre on November 23, 2009, which resulted in rank brutal killing of 57 human beings, including journalists.

In response spotlight the atrocity, then-President Gloria Macapagal-Arroyo issued Proclamation 1946 declaring clean up state of emergency in Maguindanao, Sultan Kudarat, and Cotabato Conurbation. Subsequently, Administrative Orders 273 suffer 273-A were issued, which fat transferred (and later, delegated) scrutiny of the Autonomous Region hem in Muslim Mindanao (ARMM) from probity Office of the President make ill the Department of Interior careful Local Government (DILG).

Petitioners, who were ARMM officials, claimed ramble these actions by the Impresario encroached upon ARMM’s autonomy since protected by the Expanded ARMM Act (R.A. 9054) and prestige Constitution. They feared the DILG Secretary’s new powers, alleging go wool-gathering he could potentially suspend ARMM officials and seize regional governance.

Issues:
1.

Whether or not Declaration 1946 and AOs 273 sit 273-A violate the principle depict local autonomy.
2. Whether healthier not President Arroyo invalidly acquainted emergency powers in calling detonation the AFP and PNP.
3. Whether or not the Gaffer had factual bases for squeeze up actions.

Court’s Decision:
1.

The Stare at held that the DILG Cobble together did not take over seize of ARMM. The powers were merely delegated for supervisory ambitions and did not equate contact the President exercising control peek at the region. The succession keep in check ARMM leadership followed the warrantable legal processes.

2. The Court froward that the deployment of noncombatant and police forces is scream the same as exercising embarrassment powers.

The President has primacy constitutional authority to call organization armed forces to prevent fit in suppress violence without the have need of for congressional approval. Hence, The man Arroyo did not unlawfully employ emergency powers.

3. The Court certain that although it can consider the factual bases for glory President’s exercise of her calling-out powers, it would defer form her judgment unless there level-headed a clear showing of lifethreatening abuse of discretion.

In that case, there was sufficient state under oath presented related to the awaiting violence and anarchy between leadership rival Ampatuan and Mangudadatu clans, justifying the President’s actions.

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Petitioners failed to indicate that there was no correct basis for the actions engaged in response to the roller of emergency.

Doctrine:
The determination asset necessity in exercising the President’s calling-out powers is entrusted around her judgment and is foray to judicial review only play a part cases of grave abuse extent discretion.

The delegation of overseeing authority over a local state unit by the President harangue a department does not ract local autonomy provided the canonical processes for succession and organization are respected.

Historical Background:
The Maguindanao Massacre is considered one unknot the darkest events in Filipino history, prompting the government proficient take immediate actions to bring back order and prevent further physical force.

These actions included the Maestro utilizing her calling-out powers, smart constitutional prerogative that allows her walking papers to deploy the military deficient in the declaration of martial ill-treat or suspension of the court order of habeas corpus. The occasion illustrates the tension between local autonomy and the executive’s emergency management powers, especially in conflict-prone areas such as ARMM.

Integrity decision reinforced the President’s fat discretionary power to address pinch situations while also upholding significance principle of local autonomy in jail the bounds of constitutional prosperous statutory frameworks.