Statutory Construction

Integrated Bar of the Philippines vs. Zamora

August 15, 2000
Kapunan, J.

FACTS:
Pres. Joseph Estrada called for a Joint Visibility Patrol by the Philippine
National Police and Philippine Marines in view of the alarming increase in
violent crimes in Metro Manila, i.e. bombings, robberies, kidnappings, and
carnappings. He called them Task Force Tulungan and assigned Police Chief
Superintendent Edgar Aglipay to formulate the Letter of Instruction to be
followed by the task force.
Petitioners contend that the president committed grave abuse of discretion
by deploying the military into the civilian grounds, thereby violating the
Civilian Supremacy Clause.

ISSUE/S:
1. W/N Pres. Estrada acted beyond his power to call for the joint visibility
patrol
2. W/N petitioners have legal standing to file the case
3. W/N the case is subject to judicial review

HELD:
1. No. The President, granted with the power as Commander-in-Chief, has
the authority to Call Out the armed forces for the good intention of
peace and protection of the people.
He also did not act with grave abuse of discretion because the latter
means executing capricious and whimsical exercise of judgment
whereas, the president proved that his command was for the sole
purpose of tranquility and protection of the civil liberties of the people.

2. No. In order to have legal standing, the petitioners must directly

acquire injury upon the execution of the action being appealed.
However, since the issue is of public interest, the court allowed the
case to be filed despite the lack of standing.
3. Yes. Even though the question raised by the petitioners is not of judicial
review because they questioned the wisdom of the LOI in including the
marines in the task force, the court still adjudicates the legality and
validity of the LOI in accordance with its compliance with Sec. 18, Art.
VII of the 1987 Constitution, which rewards the president with the
power as Commander-In-Chief.