Issue: Whether or not the events in Marawi City constitutes the crime of rebellion?

Facts of the Case: On May 23, President Duterte issued Proclamation No. 216 declaring a
state of martial law and suspending the privilege of the writ of habeas corpus in the
whole of Mindanao. This was issued after the series of events that unfolded in Marawi
City by the Maute Group, a terrorist-group linked with the ISIS. Within the period
required by the Constitution, both house of Congress issued separate resolutions finding
said proclamation to be satisfactorily constitutional and in accordance with the law.
Petitioners filed their opposition, arguing mainly that while there was indeed armed
public uprising in Marawi City, it does not constitute rebellion as the armed hostilities
lack the element of culpable political purpose, that is (1) the removal of allegiance the
Government or its laws the territory of the Philippines or any part thereof, or any body
of land, naval or other farmed forces; or (2) to deprive the Chief Executive or Congress,
wholly or partially, of any of their powers or prerogatives.

Ruling: The Court, speaking through Justice del Castillo, concluded that the President, in
issuing Proclamation No. 216, has sufficient factual bases tending to show that actual
rebellion exists. The President satisfactorily discharged the burden of proof, after having
deduced from the facts available to him that there was an armed public uprising, and
the following grounds satisfy the requisite of culpable political purpose:

a. Lawless armed groups have taken up arms and committed public uprising against
the duly constituted government and against the people of Mindanao, for the
purpose of removing Mindanao – starting with the city of Marawi, Lanao del Sur
– from its allegiance to the Government and its laws.
b. In doing so, they deprived the President of his powers and prerogatives to
enforce the laws of the land and to maintain public order and safety in
Mindanao, to the great damage, prejudice, and detriment of the people therein
and the nation as a whole.
c. That the series of events that happened on May 23, 2017 put on display the
groups clear intention to establish an Islamic State, and that these activities
constitute not simply a display of force, but a clear attempt to establish the
groups’ seat of power in Marawi City.
d. Cutting off vital lines for transportation and power; the recruitment of young
Muslims to further expand their ranks and strengthen their force; the armed
consolidation of their members throughout the city; the decimation of a
segment of the city population who resists; and the brazen display of DAESH
flags constitute a clear, pronounced, and unmistakable intent to remove Marawi
City, and eventually the rest of Mindanao, from its allegiance to the
Government.
Additional notes:

Elements of Rebellion under Article 134:

1. That there be:

a. public uprising; and

b. taking up arms against the Government; AND

2. That the purpose of the uprising or movement is either:

a. To remove from the allegiance to said Government or its laws the

territory of the Philippines or any part thereof, or any body of land, naval
or other farmed forces; or
b. To deprive the Chief Executive or Congress, wholly or partially, of any of
their powers or prerogatives.