UNIVERSITY OF CAGAYAN VALLEY

JURIS DOCTOR-1
GROUP-A
Locus Standi or Legal Standing has been defined as a personal and substantial interest in a case
such that the party has sustained or will sustain direct injury as a result of the governmental act
that is being challenged. The gist of the question on standing is whether a party alleges such
personal stake in the outcome of the controversy as to assure that concrete adverseness which
sharpens the presentation of issues upon which the court depends for illumination of difficult
constitutional questions. Thus, as a general rule, a party is allowed to “raise a constitutional
question” when:
(1) he can show that he will personally suffer some actual or threatened injury because of the
allegedly illegal conduct of the government;
(2) the injury is fairly traceable to the challenged action; and
(3) the injury is likely to be redressed by a favorable action.
Jurisprudence defines interest as "material interest, an interest in issue and to be affected by the
decree, as distinguished from mere interest in the question involved, or a mere incidental interest.
By real interest is meant a present substantial interest, as distinguished from a mere expectancy
or a future, contingent, subordinate, or consequential interest."
In law, as much in life are equally important in all civilized nations. The ancient Latin doctrine
maxim says ‘SALUS POPULI EST SUPREMA LEX’ (THE WELFARE OF THE PEOPLE IS
THE SUPREME LAW) applies in the latest trend of debate between constitutional rights and
welfare of the nation and its people in the Anti-terrorism act of 2020. The 37 petitions filed
against the existence of R.A.11479 are now pending at the Supreme Court. The petitioners
question the constitutionality of the law with their issues of deprivation of RIGHTS particularly
freedom of speech, Freedom of the press, Freedom of expression, Freedom of Privacy,
Constitutional due process, and several other moot and academic issues including the over
breadth definition of TERRORISM.
This is a position paper in which issues center on whether the petitioners have legal
standing to sue and if ATA should be declared unconstitutional in its entirety should the court
finds the definition of terrorism as well as the powers of the Anti-Terror Council (ATC)
constitutionally infirm.
FACTS:
The anti-terrorism act of 2020 repeals the ‘Human security act’ of 2007, Making changes to
some of the provisions as well as the definition under TERRORISM (SEC.4). Sen.Panfilo
Lacson one of the principal authors of the law (R.A.11479) of 2020, said that the Human security
act of 2007 was a dead standing law because it has been severely underutilized as it only resulted
in a single convicted felon and only one prescribed organization, the Abu Sayyaf. The law was
prepared by the committee on national defense and security, peace, unification and reconciliation
and finance and it was approved by the senate on February 26, 2020 with following authors:
1. PANFILO LACSON,
2. LITO LAPID,
3. MA.IMELDA MARCOS,
4. RAMON REVILLA,
5. RONALD DELA ROSA, and
6. VICENTE SOTTO III

There are only two senators dissented; Risa Hontiveros Baracquel and Francis Pangilinan.

The law was signed by PRESIDENT RODRIGO ROA DUTERTE on July 3 2020, in the
midst of the ongoing COVID 19 pandemic and serves as an anvil of Philippines continued fight
against terrorism. Proponents of the law have cited the siege of Marawi in 2017, Abu Sayyaf
criminal activities, New People’s Army communist rebels and other supposed emerging threat to
the public safety and national security.

ISSUES TO BE RESLOVED
I.
Whether the petitioners have the legal standing to sue;
II.
If Anti-terrorism Act or R.A.11479 should be declared unconstitutional and its entirety if the
court finds the definition of terrorism, as well as the powers of the Anti-Terrorism Council
(ATC), are constitutionally infirm;
The second issue can be divided into two sub-issues, (II-A) the definition of terrorism and (II-B)
the powers of the Anti-Terror Council (ATC) as basis in declaring the ATA unconstitutional and
its entirety.

PETITIONERS’ ARGUMENT
I.
LOCUS STANDI
In the statement of Atty. Jose Anselmo I. Cadiz, one of the counsel for the petitioners, the
petitioners are invoking the Honorable Court’s judicial power under the Constitution, to assert
the supremacy of the people’s fundamental rights under the Constitution.
 He asserts that the petitioners have legal standing to file the petitions, as the instant case
concerns bill of rights, which are public rights. Some of the petitioners have even been
characterized by state elements as aiding terrorists. There is thus a credible threat of prosecution
against said petitioners.

He stated that the Court is sanctioned under the law. This is a case of transcendental
importance. Considering that the houses of Congress enacted the Anti-Terror Law, and
considering further that the question of constitutionality is raised at the earliest opportunity and is
the lis mota of the case, it is proper for this Honorable Court to resolve the same. He quoted
People vs. Sapla:

“The Bill of Rights should never be sacrificed on the altar of convenience. Otherwise, the
malevolent mantle of the rule of men dislodges the rule of law.”

He further added that in truth and in the grand scheme of things, this is not a battle between
the Petitioners and Government, nor their respective counsels, but it is a colossal battle between
the Constitution and the Anti-Terror Law. Presently, the Anti-Terror Law is running roughshod
over the constitution, particularly the Bill of Rights.

The petitioners then come to plead to the Supreme Court to snatch the constitution from the
jaws of defeat and restore its primacy, against the Anti-Terror Law.

During the interpellation of Justice Carandang with Atty. Anselmo Cadiz, Justice Carandang
asked Atty. Cadiz if aside from the freezing of deposits of the Rural Missionaries of the
Philippines or the RMP and the 2 Aetas, if the other petitioners have been charged or prosecuted
under the law. Atty. Cadiz cited the filing of a pleading of Retired Justice Carpio that threatens
the petitioner thru the facebook account of General Antonio Parlade which provided “the
Supreme Court will soon be hearing petitions against the Anti-terrorism and that they should be
watchful of these individuals, groups and organizations, opposing a law that will protect our
citizens from terrorists. And in his concluding sentences he said that the Day of Judgment is
upon you and the Filipino people who have suffered enough from the malignant hands of the
CPP-NPA-NDF, of which you are part of sit-in judgment. Very soon blood deaths will be settled.
The long arm of the law will catch up on you and your supporters.” The petitioners assert that
this is an actual threat to the safety and liberty of some petitioners, thus giving them locus standi.

During the interpellation between Justice Caguioa and Atty Diokno on February 16, 2021,
Justice Caguioa ask about facial challenge. As a general rule facial challenge is not allowed
against a penal statute but there is an exemption as laid down in the case of Dissini vs Executive
Secretary where it involves restriction of freedom of speech and right to privacy.
It is also reiterated there is a curtailment of rights, 15 sections of the bill of rights is infringed.
These are liberty from unreasonable arrest and detention, unreasonable search and seizure,
privacy, freedom to association, right to travel and violation of due process, denial of bail, and
presumption of innocence.
Atty Diokno reiterated that they have a legal standing because the ATA may bring imminent
danger to constitutional rights, more so, the petitioners are tagged as terrorist in protecting their
rights which make them vulnerable from possible abuses of the law and if the law is in
contravention with the Constitution, it is subject at all times to judicial review.
Atty Molo also said that section 29 violates Section 2 of the Constitution because it
grants the ATC the power to issue a piece of paper to detain a person. As stated in the
Constitution, only a judge can issue a warrant upon probable cause. There is also a violation in
the separation of powers in Section 29 of the ATC. Under the same section you can also be
arrested for being suspected as a terrorist.
Also, during the oral arguments, Atty. Alfredo Mollo III, representing the petitioners in
GR No. 252736 manifested that legal standing has many forms. An actual case of controversy in
Constitutional Law is not the same as pending case.
Atty. Jose Anselmo I. Cadiz, representing the petitioners in GR No. 253124 contends that the
petitioners have the legal standing to initiate petitions and the issues raised by them were ripe for
judicial review.

II.
DECLARING THE ANTI-TERRORISM ACT IN ITS ENTIRETY
UNCONSTITUTIONAL
II-A
Petitioners noted the usual argument that Section 4 of the ATA states that the definition
of terrorism “shall not include advocacy, protest, dissent, stoppage of work, industrial or mass
action, and other similar exercises of civil and political rights.”
Diokno cited that there is a catch to this exception: the exercise of these rights must not be
“intended to cause death or serious physical harm to a person, to endanger a person’s life, or to
create a serious risk to public safety.”

They pointed out that this “leaves it up to the law enforcer to decide” if rallies or even
social media posts are intended to cause harm, endanger lives or create safety risks to justify
arresting government critics and charging them with violations of the ATA.
Diokno said in other crimes, intent is usually “presumed from the criminal act.” But,
under the ATA, intent to cause harm, endanger lives or create safety risks is supposed to be
determined even from acts that are otherwise “not criminal.”
He was referring to the absence of “predicate crimes” in the ATA – unlike the now-repealed
Human Security Act (HSA) that enumerated criminal acts such as murder, rebellion, piracy,
kidnapping, arson, hijacking, or illegal possession of firearms and explosives, as acts that may be
qualified as terrorist acts depending on the intent and effect.
Section 4 of the ATA merely defines terrorism as acts “intended to” cause death or
injury, endanger lives, and cause extensive damage or destruction to public and private property
and critical infrastructure. Based on the law, clearer activities include the development,
acquisition, possession or use of weapons, release of dangerous substances, and causing fires,
floods or explosions.
Senior Associate Justice Estela Perlas-Bernabe asked if Congress is commanded to define every
word and term used in the laws. Diokno replied that while not every word has to be defined, “the
operative words that give rise to elements of crime” must be made clear.
Bernabe also questioned why the SC should void the law for vagueness, if the “legislative
will or intent” is apparent despite the general wording.
Diokno maintained that the standards set out in the law are not complete. He reiterated that
Congress “allows the state to simply presume the existence of intent from the citizen’s acts, even
if the acts themselves do not constitute a crime.”
“Anyone, therefore, who tweets for people to attend a peaceful rally could be arrested for
engaging in acts intended to endanger a person’s life due to the danger of COVID infection,” he
explained.
II-B

The assailed law, RA 1147, is not in sheep’s clothing. Frequently an issue of this sort will
come before the Court clad, so to speak, in sheep's clothing: the potential of the asserted
principle to effect important change in the equilibrium of power is not immediately evident, and
must be discerned by a careful and perceptive analysis. But this wolf comes as a wolf.
Section 29, RA 11479, violates separation of powers inasmuch as it contravenes free
access to courts (Sections 11, Article III), it empowers the military or police officer to arrest,
search and seize persons and things (Sections 2, Article III), and it trespasses the rulemaking
power this Honorable Court (Section 5 par. 5, Article VIII).
On its face the RA 11479 decriminalized deprivation of right to liberty and personal
security, it allows imprisonment for up to 24 days without conviction, it removes the privilege of
writ of habeas corpus, it denies right to bail, it is repugnant to speedy disposition of cases, it
violates due process of law, and it negate equal protection of law, among many others.
Section 29, RA 11479 provides:
SEC. 29. Detention Without Judicial Warrant of Arrest.- The provisions of Article 125 of
the Revised Penal Code to the contrary notwithstanding, any law enforcement agent or
military personnel, who, having been duly authorized in writing by the ATC has taken
custody of a person suspected of committing any of the acts defined and penalized under
Sections 4, 5, 6, 1, 8, 9, 10, 11 and 12 of this Act, shall, without incurring any criminal
liability for delay in the delivery of detained persons to the proper judicial authorities,
deliver said suspected person to the proper judicial authority within a period of fourteen
(14) calendar days counted from the moment the said suspected person has been
apprehended or arrested, detained, and taken into custody by the law enforcement agent
 or military personnel. The period of detention may be extended to a maximum period of
ten (10) calendar days if it is established that (1) further detention of the person/s is
necessary to preserve evidence related to terrorism or complete the investigation; (2)
further detention of the person/s is necessary to prevent the commission of another
terrorism; and (3) the investigation is being conducted properly and without delay.
Immediately after taking custody of a person suspected of committing terrorism or any
member of a group of persons, organization or association proscribed under Section 26
hereof, the law enforcement agent or military personnel shall notify in writing the judge
of the court nearest the place of apprehension or arrest of the following facts: (a) the
time, date, and manner of arrest; (b) the location or locations of the detained suspect/s
and (c) the physical and mental condition of the detained suspect/s. The law enforcement
agent or military personnel shall likewise furnish the ATC and the Commission on
Human Rights (CHR) of the written notice given to the judge.
"The Constitution," as aptly stated in one case, "is a law for rulers and for people equally in
war and in peace and covers with the shield of its protection all classes of men at all times and
under all circumstances." And it is for this reason that our courts must be open for accessibility
as enunciated in Section 11, Article III of the Constitution which provides that free access to the
courts and quasi-judicial bodies shall not be denied.
Ironically, Section 29 of RA 11479 provides that the courts are not accessible for 14 to 24
days to the “suspected person” therein. As the latter shall not to be delivered to the court for
judicial custody. This is implicit in Section 29 in exempting military officer from the criminal
liability in Article 125 of the Revised Penal Code (“RPC” for brevity)
Section 29, therefore, shut the doors of our courts up to 24 days to the “suspected person.”
The moment a person is deprived of liberty, his or her entitlement to due process of law
arises. Our deduction is based on a correlated provision in Section 2, Article III on the
inviolability of the right to personal security which can on only be pierced by a judge who can
seize, under a strict constitutional guideline, a person thru a warrant of arrest. And presumption
of innocent in Section 14 (2), Article III.
Section 2, Article III of the Constitution governs the exclusive judicial power of the courts in
the issuance of arrest or search warrant.
The State cannot in a cavalier fashion intrude into the persons of its citizens as well as into
their houses, papers and effects. The constitutional provision sheathes the private individual
with an impenetrable armor against unreasonable searches and seizures. 66 It protects the privacy
and sanctity of the person himself against unlawful arrests and other forms of restraint.
Given the significance of this right, the courts must be vigilant in preventing its stealthy
encroachment or gradual depreciation and ensure that the safeguards put in place for its
protection are observed.
Section 29 echoes a chilling effect to the constitutional rights of the people to due process.
 The assailed provision of the law categorically provides that “any law enforcement agent or
military personnel, who, having been duly authorized in writing by the ATC has taken custody of
a person suspected of committing any of the acts defined and penalized.”
Section 29 is clear that: a mere suspect may be subjected to a warrantless arrest by the law
enforcement agent or military personnel with a written authorization by the ATC to make an
arrest and detain a person.
This power in Section 29 is usurpation of the exclusive judicial powers of judges in Section
2, Article III. The constitutional right to liberty and personal security is inviolable which can
only interfered with by courts upon application by complainant, presentation of evidence,
satisfaction of probable cause, and issuance of warrant of arrest.
The power of the court in Section 12, Article III is exclusive. It is not sharable to the other
two branches of the government. The Congress, in Section 29, cannot diminish it by allocating
portion of such power, even one specific offense, to the Executive Branch.
Section 2, Article III provides for the court’s jurisdiction as to the custody of person. The
Constitution is clear that the court shall exercise exclusive jurisdiction to issue warrant of arrest
but inherent that is the jurisdiction over any person whose liberty by virtue of making a person to
answer for penal laws.
In Section 29, it legalized up to 24 days custody of a person to the military or police officer
authorized by the ATC. This unconstitutional inasmuch as it vests jurisdiction over the custody
of a person who are to answer for violation of a penal law, RA 11479. Detention by any law
enforcer is administrative detention as opposed to custody of law which is essentially a judicial
process which requires as we have discussed above strict constitutional guidelines.
To make imprisonment lawful, it must either be, by process from the courts of judicature, or
by warrant from some legal officer, having authority to commit to prison; which warrant must be
in writing, under the hand and seal of the magistrate, and express the causes of the commitment.
When a person is under the custody of law, he or her rights is secured by the court’s
jurisdiction and powers. He or she is under the direct judicial oversight of the judges who are
presumptively competent, impartial, and independent. Since our judges are not themselves the
arresting and detaining officers, they can objectively dispense with their constitutional judicial
duties expected of them.
On the contrary, military or police officers has suspected person under administrative
detention. There is no guarantee that he or she can be protected by the Constitution. Military or
police officers, with all respect, do not have that constitutional prescription imposed to the judge
on accountability of competency, impartiality and independence.
In our jurisdiction, the only allowable administrative detention are in deportation
proceedings, civil commitment of the mentally ill and temporary detention in quarantine of the
infectious. These exceptions are permitted because they “do not partake of the nature of a
criminal action. This is allowable because the person is not detain to answer for a crime.
 Section 2, Article III in the light of the rules on arrest it mandated. This provision is
immutable. It cannot be altered by any of the branch of the government, not even this Honorable
Court.
Section 2, Article III provides for a specific judicial process upon which a person can be
seized and detained by virtue of a warrant issued by a judge.
The issuance of arrest, we must underscore, does not demand a ministerial function. It cannot
be compared with a judge’s duty of issuance of a summons, in civil cases, where a judge
authorizes its issuance if a complaint is sufficient in form and substance. In the issuance of a
warrant under Section 1, Article III a sworn complain, sufficient in substance and form, does not
ipso facto impose duty to the judge to automatically issue a warrant. The judge is required to
follow a stringent constitutional procedure in order curtail anyone’s right to liberty and personal
security.
The judge must: (a) see and personally examine the complainant and her or his witnesses; (b)
requires them under oath or affirmation (this oath and affirmation entitles an effective remedy to
a victim since a cause of action on perjury arises make false statements); (c) ask the complainant
and the witnesses, not a mere perfunctory question, searching question to determine probable
cause; and (d) be satisfied that the evidence presented overcome the burden of proof of probable
cause NOT a bare suspicion.
The foregoing constitutional requirement was diminished by Section 29 inasmuch as it is not
a judge but the ATC or the officer therein authorized to curtail right to liberty and security of
person. No complainant and witnesses are required neither complaint under oath or
affirmation.75 No searching question is observed to seek the truth. And, finally, the required
evidence of probable cause was relegated to a bare suspicion.
Finally, the neutrality, detachment and independence that judges are supposed to possess is
precisely the reason the framers of the 1987 Constitution have reposed upon them alone the
power to issue warrants of arrest. To vest the same to a branch of government, which is also
charged with prosecutorial powers, would make such branch the accused's adversary and
accuser, his judge and jury.
Section 5 (5) of Section VIII of the 1987 Constitution, the Supreme Court shall have the
power to promulgate rules concerning the protection and enforcement of constitutional rights.
This power is now outside the domain of the other two branches of the government.
This provision expanded the rule making power of this Court for (1) it extended its power not
only to cover pleading, practice and procedure in all courts, admission to the practice of law and
the integration of the Bar but also to encompass the protection and enforcement of constitutional
rights and legal assistance to the underprivileged, and (2) it no longer contained the restriction
that said rules "may be repealed, altered or supplemented by the Batasang Pambansa.” In fine,
the power to promulgate rules of pleading, practice and procedure is no longer shared by this
Court with Congress, more so with the Executive.
 The separation of powers among the three co-equal branches of our government has erected
an impregnable wall that keeps the power to promulgate rules of pleading, practice and
procedure within the sole province of this Court.80 And the other branches trespass upon this
prerogative if they enact laws or issue orders that effectively repeal, alter or modify any of the
procedural rules promulgated by the Court.
In Estipona, Jr. y Asuela v. Lobrigo,82 it cited cases wherein it struckdown laws and rules
repugnant to this Honorable Court’s rule-making power:
The petitioners cited several jurisprudences that have rejected previous attempts on the part
of the Congress, in the exercise of its legislative power, to amend the Rules of Court (Rules),
to wit:
1. Fabian v. Desierto—Appeal from the decision of the Office of the Ombudsman in
an administrative disciplinary case should be taken to the Court of Appeals under the
provisions of Rule 43 of the Rules instead of appeal by certiorari under Rule 45 as
provided in Section 27 of R.A. No. 6770.
2. Cathay Metal Corporation v. Laguna West MultiPurpose Cooperative, Inc— The
Cooperative Code provisions on notices cannot replace the rules on summons under Rule
14 of the Rules
3. RE: Petition for Recognition of the Exemption of the GSIS from Payment of Legal
Fees; Baguio Market Vendors Multi-Purpose Cooperative (BAMARVEMPCO) v. Hon.
Judge Cabato-Cortes; In Re: Exemption of the National Power Corporation from
Payment of Filing/Docket Fees; and Rep. of the Phils. v. Hon. Mangotara, et al.—
Despite statutory provisions, the GSIS, BAMARVEMPCO, and NPC are not exempt
from the payment of legal fees imposed by Rule 141 of the Rules.
4. Carpio-Morales v. Court of Appeals (Sixth Division)—The first paragraph of
Section 14 of R.A. No. 6770, which prohibits courts except the Supreme Court from
issuing temporary restraining order and/or writ of preliminary injunction to enjoin an
investigation conducted by the Ombudsman, is unconstitutional as it contravenes Rule 58
of the Rules.
Considering that the aforesaid laws effectively modified the Rules, this Court asserted its
discretion to amend, repeal or even establish new rules of procedure, to the exclusion of the
legislative and executive branches of government. To reiterate, the Court's authority to
promulgate rules on pleading, practice, and procedure is exclusive and one of the safeguards of
Our institutional independence.

OFFICE OF THE SOLICITORS GENERAL’S ARGUMENT

I.
 The respondents’ argument started thru Solicitor General Jose Calida. In his opening
statement, he seeks for the outright dismissal of the case for various reasons. One is there are
other parties not before this court with direct and specific interests.
The OSG cited the criminal cases filed against 2 Aetas at the Regional Trial Court of
Olongapo City for violation of the anti-Terrorism Act and another three cases against three
individuals in Negros Occidental. He further stated that four criminal cases have been filed in
Jolo Sulu against 13 individuals and several John and Peter Does for violation of sections 4a and
4b of the anti-terrorism Act. The accused in these cases led by Mud Zimar are indicted for the
August 24 2020 Jolo bombings. Another case for violation of Section 4b is pending before the
RTC of Gubat Sorsogon. Recently, the ATC applied section 25 of the anti-Terrorism Act and
designated the Communist Party of the Philippines, New People's Army as terrorist organization.
These individuals and groups now stand to sustain direct and personal injury as a consequence of
the implementation of the law. In contrast, herein petitioners cannot even make the same claim.
The OSG further stated that the principle of locus standi has long been settled. It was for
more than just a generalized grievance. It must be a personal and substantial interest, whereby a
person will incur direct injury due to the governmental act assailed. It should be material, not
merely incidental. There should be a present substantial interest, and not a mere expectancy, or a
future contingent, subordinate or consequential interest.
There are now exists parties with more direct and specific interest in the very issues being
raised before the Supreme Court than herein petitioners. To reiterate, criminal cases have been
filed already against 2 aetas at the Regional Trial Court of Olongapo City for violation of the
anti-Terrorism Act. Petitioners do not also allege any link to the two aetas. This automatically
divests petitioners, the right to invoke the doctrine of transcendental importance, on which their
whole theory for locus standi depends on. Unlike the 2 aetas who lost their liberty, the petitioners
did not suffer any direct or indirect injury that will vest them with locus standi.
The OSG quoted the court’s decision in Southern Hemisphere versus ATC, “More
important, there are other parties not before the court with direct and specific interests in the
question being raised, our recent development is the filing of the first case of proscription under
Section 17 of RA 9372 by the Department of Justice before the Basilan Regional Trial Court
against the Abu Sayyaf group. Petitioner organizations do not in the least allege any link to the
Abu Sayyaf group.”
During the interpellation between Associate Justice Rosamari Carandang and ASG
Galandinez, it was asked to reconcile the respondents’ argument that petitioners have no standing
to suit all petitioners are alleging that this case involves constitutional issues which are all
transcendental importance and paramount public interest. ASG Galandinez answered that all
petitions have not been able to satisfactory show the attendance of known exemptions to the
principle of judicial hierarchy particularly the transcendental importance of this case, the
presence of a conventional issue and its novelty.
Associate Justice Carandang also cited that the petitioners are alleging that there are
several constitutional issues in this case like infringement of freedom of speech, freedom of
religion, freedom of basic constitutional issues that need to be resolved in this case, wherein the
ASG answered that it is their submission that these are not to be resolved in this case. These are
mere motherhood statements and petitioners have not called actual circumstances that would
apply to them. The SC is not a trier of facts, the alleged facts must be proved and must follow the
doctrine of hierarchy of courts for the SC is not a trier of facts.
Associate Justice Carandang further inquired if the constitutional issues involve in this
case will be decided by the RTC, to which the ASG answered positively. Associate Justice
Carandang then asked the ASG to cite as resolution wherein the basic constitutional issue of a
violation of freedom of religion, freedom of speech, freedom of association has been considered
and ruled upon by the RTC but the ASG failed to cite one.
During the May 11 oral arguments, Justice Leonen raised curtained facts such as reports
about the spokesperson of NTF-ELCAC condemning the petitioners, the bloody Sunday in
Southern Luzon and Community Pantries but ASG Galandines maintained their position that
they are not party of a case or controversy under ATA. According to ASG Galandines, there are
constitutional requirements before the cases are heard in the SC. The SC is not a court to receive
evidence and to receive cross examination of evidence and that there are institutions within the
judiciary who deal on those matters.
Justice Leonen pointed that if they dismiss the current petitions on the ground that they
choose not to exercise the power of judicial review will mean that there is no person more
directly, materially and substantially protected may in the near future challenge a portion or if it
affects seem personally, directly and substantially a large chunk of the law. He, however pointed
out that the danger so in effect there are cases where judicial review is only discretionary power
on the part of the SC, a duty on the part of the court or constitutional inappropriate.
Justice Leonen further states that there is extraordinary jurisdiction in the progressive 1987
Constitution, it does not mean the court can do the role of the President or Congress in order to
just say, everything is abuse of discretion. That even the extraordinary situation contain in
Article 8 Section 1 of the constitution can declare null and void an act of a department of
Government as a grave abuse of discretion and transgressing the constitution requires that there
must be an actual case.
On May 12, 2021 oral arguments, Chief Justice Gesmundo interpolated ASG Marissa
Galandines. According to ASG Galandines, the 37 petitioners failed to satisfy the requirements
for bringing the case before the honorable court. They lack legal standing. There is no actual case
or controversy. They have no specific interest nor specific injury which they could present before
the honorable court.
Chief Justice Gesmundo cited the incidents alleged by the petitioners for example the
sworn statements and reports of the NTF-ELCAC containing photographs and displaying their
names and logo of their organizations and referring to them as communist terrorist or bronze
officials and members of the communist party of the Philippines, new people’s army and the
national democratic front. Based on personal Knowledge and third-person accounts at around the
time of the adaption of the ATA, petitioners alleged that one of their leaders was summarily
executed, that their members and officers were subjected to surveillance and threats of reign and
that during a peaceful protest in August 2020, some of their members were arrested and their
publications confiscated, now a moment ago we established that CPP NPA have been designated
as terrorist organizations by the ATC hence coupling with said declaration with allegations of
petitioners is there sufficient basis to establish the petitioners are under credible threat of
persecution under the ATA law but ASG Galandines submits that the factual circumstances
narrated are not in any way ATA related because the sincerest factual in nature should be tried
by the original and heard before the original trial court and not before the SC.
On the sustained direct injury raised by the reports that the petitioners are communist and
terrorist, ASG Galandines also submits that they are mere hearsays and threat of prosecution
would not cure their lack of locus standi. ASG Galandines further reiterated that factual
circumstances should not be elevated before the honorable court because it is not a trial of facts.
But according to OSG, cases presenting factual issues such as the veracity of the allegations
of torture of petitioners Gurung and Ramos must first be tried under the doctrine of Hierarchy of
Courts and following the rules of evidence, before the first the trial courts, and then on appeal by
the COA. Petitioners cannot short circuit this process by simply invoking the transcendental or
paramount importance of their cases.
II.
II-A
Terrorism is a criminal conduct with specific intent. The definition of terrorism under
Section four of the ATA is complete. It is neither vague nor impermissibly overbroad. Under
Section four of the anti-terrorism act, the crime of terrorism consists of two elements, the actus
reus, or the overt act, and the mens rea, or the criminal intent. It identifies five distinct acts, three
of which are intent specific, which in order to qualify as terrorism, must be intended to
accomplish any of the following purposes:
• To intimidate the general public and segment thereof
• to seriously destabilize or destroy fundamental structures of the country
• to create a public emergency and seriously undermine public safety as repeatedly echoed
by Chief Justice Alexander Gesmundo and Justice Mario Lopez.
To repeat, the law is clear. It is conduct coupled with specific interest, which comprises
the crime of terrorism.
II-B
Section 25 on designation is essentially an identification of a person or a person or a
group as being involved in terrorist acts. Unfortunately, petitioners misconstrue designation as a
sweeping grant of prosecutorial, legislative and judicial powers to the ATC. Nothing in the ATA
empowers the ATC to file information or issue an arrest warrant. Rather, designation is an
administrative and executive function of the anti-terrorism council to facilitate the imposition of
financial sanctions on terrorists. Designation plays a crucial role in the issuance of a freeze order
by the anti-money laundering council to prevent terrorists from accessing funds. The only
participation of the ATC in the freezing of assets is sending a request to the anti-money
laundering Council. Which is not an automatic deprivation of these designees’ property.

Designation does not inflict punishment ex post facto based on the adoption of the United
Nations Security Council, consolidated list and other requests for designation. Section 55 of the
Anti-Terrorism Act explicitly provides a prospective application therefore; the anti-terrorism
only imposes a penalty of acts or omissions committed after its effectivity. Petitioners are
mistaken in assailing the adoption of the consolidated list, which includes all individuals and
entities from across the globe that are involved in terrorism and are subject to measures imposed
by the Security Council.

Reference to consider consolidated list complies with the requirements of a valid

delegation of a list legislative power of the ATC.

The ATA defines legislative policy, which is to protect life, liberty and property from
terrorism. The ATC does not have the sole arbitrary discretion to determine who the terrorists are
and what acts constitute terrorism. It is because it is guided by the standard of probable cause.
Reasonable ground of suspicion, supported by circumstances warranting a cautious person to
believe that the proposed designee meets the requirements for designation. This is further limited
by explicit reference to offenses found in sections 4 to 12 on the anti-Terrorism Act. Hence, the
ATC cannot designate on mere suspicion contrary to petitioners’ unfounded fears.

Section 29 of the ATA does not violate a person’s right to speedy trial and speedy
disposition of cases. The petitioners should know that the right to speedy trial only attaches at the
start of the trial and not prior thereto. This right therefore does not find application during the
period of detention under Section 29 of the act. Petitioners should be reminded that the right to
speedy disposition of cases is a relative and flexible concept, and in no way can in mathematical
reckoning of the time be considered as an inordinate delay. The peculiarity surrounding the
crime of terrorism clearly justifies this period of detention.

The OSG contends that designation is an administrative function of the ATA.

Proscription is judicial in nature. The ATC as an administrative agency and it is where you get a
designation. The difference between designation of terrorist individual, and proscription cannot
be prescribed to an individual terrorist as a terrorist. The difference under designation, there is
individual, but under proscription, there is no such thing for an individual only to group of
persons in general. It is the organization that is known and not the individual itself.

It being Judicial in nature, it is guaranteed that it is within the ambit of Laws, Rules and
Regulations that no right shall be violated.

The anti-Terrorism Act satisfies the test as to whether the law is a valid exercise of police
power.
The ATA maintains probable cause in warrantless arrest. There is nothing in the ATA that
eradicates probable cause as the threshold in conducting valid warrantless arrest. It remains to be
an ironclad rule. Moreover, the phrases “suspected of” and “charged with” are used in the law as
antithesis of each other. This means that the phrase “suspected of” simply refers to someone who
has not yet been charged with before a court for violation of the anti-Terrorism Act. In other
words, a suspect in ordinary parlance. The use of the word “suspected” in Section 29 does not
wipe out the threshold of probable cause in warrantless arrest under the rules.

The ATA ensures lawful data acquisition and handling.

Neither does the anti-Terrorism Act violate the citizen’s right to privacy. The law
contains sufficient safeguards to ensure that data are lawfully acquired and properly handled.
Section 18 requires that the written surveillance order to be granted by the Court of Appeals
should contain; one, identity of the person to be surveyed/ surveilled; two, identity of the law
enforcement agent or military personnel judicially authorized to undertake surveillance activities;
three, the offense or offenses committed or being committed or sought to be prevented and
number four, the length of time within which the authorities shall be used or carried out.

This accountability driven system of checks and balances is noticeably absent in other
countries’ anti-terror legislation. In Canada for one, only the ministerial authority issued by the
Minister of National Defense is needed to greenlight any interception of private communications.
Meanwhile, India’s Information Technology Amendment Act of 2008 gives its government the
sweeping power to tap all communications without any court order, or warrant. (comparison
with other countries)

POSITION OF THE AMICUS CURIAE

I.
Retired Supreme Court (SC) Associate Justice Francis Jardeleza's formal advice to the Supreme
Court on Monday, May 17, was to junk the 37 petitions challenging the constitutionality of the
anti-terror law for lack of legal standing. According to AJ Jardeleza, following this Court’s
ruling in Southern Hemisphere Network vs. the Anti-Terrorism Council, all 37 petitions should
be dismissed, the 2010 case on similar petitions against the old law – Human Security Act –
wherein the Supreme Court junked the cases, saying there was no actual charge nor credible
threat of prosecution. The decision said the fears expressed then were merely speculative. AJ
Jardeleza further said that none of the petitioners in these cases has claimed direct, personal, or
constitutional injury, or has alleged actual prosecution under the anti- terror act as to be entitled
to relief. He cited the instance that Supreme Court did not allow intervention in the case of
Aetas Japer Gurung and Junior Ramos – both on trial for terrorism – precisely because there's
already an ongoing case at the lower court. Jardeleza said that what's allowed is a "pre-
enforcement review," but that "the same is allowed solely on grounds of vagueness” and that
“none of the petitioners have sought a pre-enforcement proceeding.”

“The liberal stance of locus standi on the basis of the transcendental importance principle has
been exemplified in Funa vs. Villar, where the SC explained that: To have a legal standing,
therefore, a suitor must show that he has sustained or will sustain a direct injury as a result of a
government action, or have a material interest in the issue affected by the challenged official act.
However, the Court has a time and again acted liberally on the locus standi requirements and has
accorded certain individuals, not otherwise directly injured, or with material interest affected, by
a constitutional issue of critical significance is at stake. The rule on locus standi is after all a
mere procedural technicality in relation to which the Court, in a catena of cases involving a
subject of transcendental import, has waived, or relaxed, thus allowing non-traditional plaintiffs,
such as concerned citizens, taxpayers, voters or legislators, to sue in the public interest, albeit
they may not have been personally injured by the operation of a law or any government act.”

II.
II-A.
While a case for pre-enforcement review of a criminal statue is possible, the same is
allowed solely on the grounds of vagueness. None of the petitioners have sought to avail of this
exemption. Following this court’s ruling, in Southern Hemisphere Network versus the ATC, all
thirty-seven (37) petitions should be dismissed. This is of course without prejudice to the
continuation of all the other cases cited by the Solicitor General. In fact, if the Solicitor General
is correct, there are three (3) other cases not before this court where there are other direct injury
plaintiffs.

The Supreme Court is not a trier of facts. Cases presenting factual issues such as the
veracity of the allegations of torture of petitioners must first be tried under the doctrine of
Hierarchy of Courts and following the rules of evidence, first before the trial courts, and then on
appeal by the CA. Petitioners cannot short circuit this process by simply invoking the
transcendental or paramount importance of their cases. This is the courts clear ruling in GIOS-
SAMAR vs Department of Trade and Communications.

For the complete avoidance of doubt, the issues raised by petitioners against the ATA are
very important. The ATA implicates civil liberties dear to all of us. There is however an absolute
dearth of facts in the present case record as of the moment to support a ruling against the ATA, at
this time. The ATA is an act of congress that supports the presumption of constitutionality.
When, and if constitutional lines are crossed as borne out by the facts, it is known where the
court’s heart lied.
On the May 11th hearing, Justice Rodil Zalameda asked the very legitimate questions
about the alleged vagueness of the terms used by the ATA to qualify the definition of terrorism
under Section 4 to wit, “To provoke the government”, to which Justice Benjamin Caguioa sagely
added the alleged vagueness of the terms, “to create an atmosphere of fear” and “to seriously
stabilize or destroy political structures of the country”.

Terms are not defined in the ATA nor in its IRR, their importance however, Southern
Hemisphere has taught us citing the case of Holder vs. Humanitarian Law Project that there is a
procedure by which the prosecution of constitutional vagueness can be brought to the Supreme
Court in a question of criminal prosecution. This is by means of a so-called pre-enforcement
review. This is of course in addition to the classical modes known to us of raising the question of
constitutional vagueness that is by certiorari at the time of arraignment or on appeal from
conviction.

II-B

In the petitions at bar, petitioners alleged that just about all the rights in our BOR will be
illicitly compromised by the ATA from due process, freedom of speech and expression, freedom
of association, freedom of religion, freedom against unreasonable search and seizure, the right to
privacy, the right against ex post facto law and bills of attainder, the right against cruel,
degrading or inhuman punishment, academic freedom, and so forth. Petitioners also alleged that
the anti-terror act wrecks the principle of separation of powers, and checks and balances, which
is the touchstone of the rule of law. Upon the other hand, the government contends that the new
restrictions on liberty imposed by the anti-terror act are benign demanded by national security
and indispensable to insure the continuing exercise of individual rights. These are the cases that
pose the greatest challenge to judicial wisdom. For in collision course is not a right versus a
wrong. Odds are not the forces of good versus the axes of evil but on loggerheads is the push of a
right versus the pull of another right. The right of individual is to be protected and the right of
national security to be upheld. Both values are recognized by the design of our Constitution.

The information soldiers received while they are most certain they have received about
the target in a while is admittedly awfully vague, at the time to carry out the option to catch him
using such information is severely limited. Would counsels proposed that our soldiers wait to
receive for complete information but risk getting these valuable targets escaped to terrorize
another day or act as best as they could and try to catch him based on the vital although limited
information they already have.

It maybe that people other than judges should issue warrants, or that detention of
terrorists for up to twenty-four (24) days without filing any charges is unreasonable. It maybe
intelligence is just too inept or maybe they are just. The US Supreme Court struck down a
provision in the Immigration and the Nationality Act for being unconstitutionally vague. The
chief justice wanted to emphasize that the US Supreme Court decision in the Maya was based on
a case record built after hearings before No. (1), an immigration judge, No. (2), the Board of
Immigration Appeals, and No. (3), the Court of Appeals for the 9 th Circuit on Appeals. Judges of
the RTC and justices of the Court of Appeals are not only equipped to receive and ascertain the
facts for this Court, they also in their own right make constitutional law. It is time we start
hearing them first by giving them the first crop at cases such as to this. The ATA’s IRR are,
however, are a far cry from the usual IRR which but copied the law and no more. The DOJ has
arrived at narrowing definitions as held in holder as to save the law from being declared
unconstitutional.

Unfortunately, none of the petitioners have sought a pre enforcement proceeding. Finally,
the case of GIOS-SAMAR which was decided in 2019. There, the Court affirmed the decision of
the hierarchy of courts as a solution to the problem of clogged court dockets. The strict
observance of the doctrine of the hierarchy of courts is a constitutional imperative not a “matter
of mere policy”. The GIOS-SAMAR cited the judiciary annual report of 2016 which indicated a
total case load of fourteen thousand four hundred ninety-one (14, 491) cases as of December
2016. In 2017 this numbered dipped to fourteen thousand four hundred eleven (14, 411), rose to
fifteen thousand (15, 000) in 2018 before dropping fourteen thousand (14, 000) at the end of
2019. Notably despite of GIOS-SAMAR and relentless efforts of the Chief Justices Teresita De
Castro, Lucas P. Bersamin and Diosdado M. Peralta to introduce reforms, the docket of cases
pending with the Court at the close of 2019 remains at nearly the same level as it was in 2016.

Threats have evolved; the changes in the nature of the threats; the metamorphosis of the
acts constituting the threats; the mutation of actors driving the change and so forth. We saw all
these changes in the different tools and techniques used by man to fight despots, to resist
tyrannicides that led to WW1 and WW2 and observe their refinements during the cold war.
In a traditional war under International Law, the rights and obligations of the warring
states, the combatants and non-combatants are defined with precision, but terrorism is not a
conventional war. It was labeled as a war; fight it like a war, and that breeds turmoil to the
protection of human rights. Given their desire to understand and contain terrorism, states have
isolated the distinctive characteristics of terrorism namely:
1. It is difficult to deter and detect because it is done in the most clandestine manner and it
is executed swiftly;
2. The magnitude of the death and destruction it can cost is unimaginable, given that the
perpetrators may have access and can use biological and chemical weapons and other
weapons of mass destructions including nuclear weapons; and
3. The difficulty of catching the perpetrators considering the porous boundaries of states and
the globalization of the world into village.
From these expert studies, the UN itself through the general assembly and the Security
Council have called on each member states to criminalize terrorism in their domestic laws,
impose new sanctions ranging from the penal, the political, economic and financial. The
internationalization of the fight against terrorism will breed novel legal problems as it will
require among others an in-depth study of the rights and the obligations of member states of UN
under its charter and an examination of the applicability of certain norms of public international
law and humanitarian law in domestic disputes. It is difficult to capture the different dimensions
of these problems as more probably than not, issues that are sui generis in nature have to be
resolved. A hint to these difficulties is the continuing failure of the UN Security Council to craft
a definition of terrorism that each member states can accept without any asterisk of reservations.
As a consequence, different models on how to combat terrorism in compliance with the call of
the UN Security Council have been developed.
This lack of consensus on the definition of terrorism will continue to be a pestering problem
considering the irreconcilable philosophy on human rights of its member states and the different
designs of their constitutions.

GROUP POSITION:
I.
LOCUS STANDI
 We agree with the position of the amicus curiae that the petitioners do not have a locus
standi to file petitions challenging the constitutionality of the ATA. Section 1 of Article VIII of
the Constitution provides constitutional requirements of locus standi. It involves settlement of
actual controversies involving infringing of fundamental rights as provided in Article III of the
Constitution. Locus standi is a remedy which individuals or organizations can file directly to the
Supreme Court to air their grievances about a certain law or government actions. Yet this remedy
is not easy as it seems because the Supreme Court cannot just accept locus standi cases without
meeting constitutional requirements. As said by Justice Leonen, the petitioners should have
waited for the case to ripen and that the Supreme Court is not the right place to file their petitions
as of the moment.

Though we agree with the petitioners that there is an imminent danger of infringing
fundamental rights most especially on freedom of speech and expression, still the petitioners are
not the rightful parties to the present case. Furthermore, the same issue has already been ruled
out by previous cases such as the Southern Hemisphere Network v. ATC challenging the
constitutionality of the Human Security Act and Imbong v. Ochoa challenging the
constitutionality of Reproductive Law. Also, in the case of Ifurung vs. Carpio Morales et.al
“Locus Standi” is defined as follows: A personal and substantial interest in the case such that the
party has sustained or will sustain a direct injury as a result of the governmental act that is being
challenged.
Though in Bayan v. Romulo, locus standi was ruled out as merely a matter of procedure
and it has been recognized that, in some cases, suits are not brought by parties who have been
personally injured by the operation of law or any government act, but by concerned citizens,
taxpayers, or voters who actually sue in the public interest. However, in Lozano v. Nograles, it
was held that while the Court has taken an increasingly liberal approach to the rule of locus
standi, evolving from the stringent requirements of “personal injury” to the broader
“transcendental importance” doctrine, such liberality is not to be abused. It is not an open
invitation for the ignorant and the ignoble to file petitions that prove nothing but their cerebral
deficit.

Following also the doctrine of res judicata, this case must also declare that the petitioners
having no locus standi to sue. Hence, in this paper, we oppose the contention of the petitioners
that they have Locus Standi in filing a petition on the legality and constitutionality of Anti-
Terrorism Act of 2021.

II.
To resolve the second issue, this group will have to look at a close glance on the two sub-
issues that it entails. There are provisions of the law that makes it UNCONSTITUTIONAL BUT
NOT IN ITS ENTIRETY.
This group partially sides with the petitioners.

Carandang and Associate Justice Marvic Leonen raised that the crime of “inciting
to rebellion” and “inciting to sedition” are already punished under Section 138 and 142 of the
Revised Penal Code. They questioned why the new crime of “inciting to commit terrorism”
under Section 9 of the ATA should be treated differently and deemed unconstitutional.
Diokno answered Carandang’s question by saying “the purposes found in the elements of
inciting to sedition are different from inciting to terrorism.”
In his interpellation of Molo, Leonen noted that inciting to sedition may have an “even broader”
definition than inciting to commit terrorism, because the former contains the words “tends to.”
He questioned if there really is a “chilling effect” that would discourage people from exercising
their rights when this did not seem to happen during the past eight decades of the Revised Penal
Code’s effectivity.
“The provisions are a bit broad. In spite of it being in the statute books, it was not enough to chill
the entire population that went to EDSA,” Leonen said, referring to the two popular uprisings
that ousted then dictator Ferdinand Marcos in 1986 and impeached president Joseph Estrada in
2001.
Molo, however, asserted that inciting to sedition is not questionable because “we know
what the prohibited behavior is – rising tumultuously.” On the other hand, inciting to commit
terrorism is vague and overbroad, because the definition of terrorism itself is vague and
overbroad.
Because the definition of terrorism is so dependent on intent and not the acts committed
by persons, Molo stated it “devolves into vagueness” and “leaves too much arbitrary discretion”
to law enforcers.

It must be further noted that all the powers of the ATC are CONSTITUTIONAL subject
to revisions. It is elementary in STATUTORY CONSTRUCTION; PROVISIONS OF A LAW
OR OF TWO LAWS TO BE HARMONIZED; IMPLIED REPEAL. — Endeavor should be
made to harmonize the provisions of a law or of two laws so that each shall be effective. In order
that one law may operate to repeal another law, the two laws must actually be inconsistent. The
former must be so repugnant as to be irreconciliable with the latter act. (U.S. v. Palacios, 33
Phil., 208.) Merely because a later enactment may relate to the same subject matter as that of an
earlier statute is not of itself sufficient to cause an implied repeal of the latter, since the new law
may be cumulative or a continuation of the old one.
A special law is not regarded as having been amended or repealed by a general law unless
the intent to repeal or alter is manifest. Generalia specialibus non derogant. And this is true
although the terms of the general act are broad enough to include the matter in the special statute.
(Manila Railroad Company v. Rafferty, 40 Phil., 224.) At any rate, in the event harmony
between provisions of this type in the same law or in two laws is impossible, the specific
provision controls unless the statute, considered in its entirely, indicates a contrary intention
upon the part of the legislature. A general law is one which embraces a class of subjects or places
and does not omit any subject or place naturally belonging to such class, while a special act is
one which relates to particular persons or things of a class. (Statutory Construction, Crawford, p.
265.)
 The ATA repealed the old Law in its entirety. That is an undisputed fact and this Group
choose to stand with the New Law subject to proper revisions.
CLOSING ARGUMENTS AND GENERALIZATON
The anti-terror law or R.A.11479 is more than a law, It is a national call of need and of a call of
JUSTICE. A justice for those who are a victim of oppression, Justice for those who lost their
brighter future in following fraudulent ideologies, Justice for those elders who lost their children
who have incorruptibly brainwashed by terrorist political atrocities by decades of warfare,
Justice for indigenous people who have been used as human shields and molested by new
people’s army all around the native land, Justice for those soldiers family who lost their walls,
Their Head in paying their lives in an open battlefield where evils of war are present, Justice for
those who lend a hand to our economy who have been a victim of extortion and arson by non-
paying of terrorist revolutionary taxes, Justice for those who suffer in losing their homes and
shelters, Their livelihood and properties in recent attacks on the south, and Justice for our
fatherland that is now dispirited due to unresolved problem of terrorist activities all throughout
the country.
No to mention the virulent battles of the past brought by terrorist extremist atrocities groups. The
recent Battle of marawi siege, Zamboanga siege, The deaths of SAF44, The Maguindanao
massacre , The countless ambuscades, executions, and abductions brought by decades of clashes,
The countless lives lost and deaths of young people and their families have gained the evils of
war thru fraudulent fallacies and ideologies of communist terrorist groups. Let’s give and
mention the honor the begotten sacrifices of our soldiers who paid their holy lives and limb in
combat of terrorism.

We should NEVER repeat the history of 1986, This is when the usurper president herself in
the exercise of her administrative executive functions in her administration pardoned all terrorist
detainee and state enemies. The most figurative terrorist in the person of Jose maria sison had
released from his long desire revenge liberty against the government. Jose maria sison or Joma
was arrested and apprehended in the province of La union on November of 1977 in operation
(strikehunt Ka Belen) by then the late legend Gov. Rodolfo ‘AGILA ‘Aguinaldo who used to be
a former military commander of the legendary Philippine Constabulary. The said operation was a
bloody and hardened by its opportunistic execution sealed by the lives of PC troopers. Such
‘FATAL FAUX PAS’ of our history should never been repeated again in this current
administration in pursuit of Justice and peace. The proclamation 1081 of September 21,1972
otherwise known as MARTIAL LAW was more executive and less legislative execution. The
presidential proclamation had never questioned its constitutionality before the high court and the
outcome became very noteworthy in our history. The criminality rate and insurgency
dramatically reduced by the apprehension of both heads of criminal syndicates and terrorist
insurgents. It serves as the Neptune sphere for the government in combating anarchy in the
country in the administration of President Ferdinand Marcos. The recent Anti-terror law was
more legislative and democratic act. It was made thru the deliberations of valid legislative
exercise and with secondary executive confirmation. Ergo, We vehemently concur with all mind
and hearts that the ANTITERRORISM LAW OR R.A.11479 is a legislative constitutional
exercise and valid administrative executive exercise of state police power. It is more than a law
for it is more morally define of national calling of sovereign Filipino people. Long live people of
MAHARLIKA (Philippines)