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271059/271347/E-02472/E-04036 Representative Edcel C. Lagman, substituted by Albay First District Representative Krisel B. Lagman, et al. Vs. The Congress of the Philippines, et al./Aquilino “Koko” Pimentel III and Pantaleo “Bebot” Alvarez Vs. Lucas P. Bersamin, in his capacity as executive secretary, and Amenah F. Pangandaman, in her capacity as secretary of the Department of Budget and Management/Filipinos for Peace, Justice and Progress Movement, Inc. (FPJPM), represented by its president and chairperson, Joseph F. Cadsawan, and Gloria T. Puzon, chapter Officer Vs. The House of Representatives, et al./Edgar R. Erice and Leila De Lima Vs. The Senate of the Philippines, et al. — Official PDF

271059/271347/E-02472/E-04036 — Promulgated October 7, 2026 · 2026 · Supreme Court 2026 / Decision or signed resolution

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DIGITAL P. 30 / 121
Decision 30 G.R. Nos. 271059, 271347, E-02472 and E-04036 The closest statutory definitions of the terms "public calamity" and "emergency" found in our laws are those provided under Republic Act No. IO 121 or the Philippine Disaster Risk Reduction and Management Act of 2010. The law provides: Section 3. Definition of Terms. - For purposes of this Act; ·the following shall refer. To: (r) "Emergency" - unforeseen or sudden occurrence, especially danger, demanding immediate action. (ll) "State of Calamity" - a condition involving mass casualty and/or major damages to property, disruption of means of livelihoods, roads and normal way of life of people in the affected areas as a result of the • occurrence of natural or human-induced hazard. 160 In David v. Macapagal-Arroyo, 161 the Court had the opportunity to discuss what constitutes an "emergency." The Court explained: Emergency, as a generic term_, connotes the existence of conditions suddenly intensifying the degree of existing danger to life or well-being · beyond that which-is accepted as normal. Implicit in [these] definitions are the elements of intensity, variety, and perception. Emergencies, as_ perceived by legislature or executive in the United States since 1933, have been occasioned by a wide range of situations, classifiable under three (3) principal heads: a) economic, b) natural disaster, and c) national security. "Emergency," as contemplated in our Constitution, is of the same breadth. lt may include rebellion, economic crisis, pestilence or epidemic, typhoon, flood, or other similar catastrophe of nationwide proportions or effect. 162 These definitions encompass a broad and dynamic concept of the terms "public calamity" and "emergency." Even then, it must be borne in mind that while statutory and jurisprudential definitions provide guidance, these cannot limit the concept of urgency or calamity in the constitutional provision that allows the president to certify bills as urgent. This is in accordance with the doctrine on constitutional supremacy, which prescribes that the Constitution is the fundamental and paramount law of the land that establishes not only the •fra1~ework of our government, the powers, duties '.and responsibilities of each / -✓ 160 Republic Act No. \OJ 21 (20 I 0), Philippine Disaster Philippine Disaster Risk Reduction and Management Act of20 I 0, secs. 3(r) and (II). "'' 522 Phil. 705 (2006) [Per J. Sandoval-Gutie1Tez, En Banc]. 11' 2 Id. at790-79!.