In 2011, the Supreme Court upholds former President Gloria Macapagal-Arroyo’s proclamation of a state of emergency in Maguindanao, Cotabato, and Sultan Kudarat shortly after the Maguindanao massacre for failure of petitioners to demonstrate that the proclamation lacked factual bases in G.R. No. 190259 (Ampatuan v. Puno)

June 7, 2011