Aquino vs Minister of Defense Juan Ponce Enrile

Enrile (then Minister of National Defense), pursuant to the order of Marcos issued and ordered the
arrest of a number of individuals including Benigno Aquino Jr even without any charge against them.
Hence, Aquino and some others filed for habeas corpus against Juan Ponce Enrile. Enriles answer
contained a common and special affirmative defense that the arrest is valid pursuant to Marcos
declaration of Martial Law.

ISSUE: Whether or not Aquinos detention is legal in accordance to the declaration of Martial Law.

HELD: The Constitution provides that in case of invasion, insurrection or rebellion, or imminent danger
against the state, when public safety requires it, the President may suspend the privilege of the writ of
habeas corpus or place the Philippines or any part therein under Martial Law. In the case at bar, the state
of rebellion plaguing the country has not yet disappeared, therefore, there is a clear and imminent
danger against the state. The arrest is then a valid exercise pursuant to the Presidents order.