IBP v.

Zamora
9/17/2014
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Constitutional Law. Political Law. Fundamental Principles and State Policies. Article II, Section 3. Civilian
Supremacy.
IBP v. ZAMORA
338 SCRA 81
FACTS:
The President ordered the PNP and the Marines to conduct joint visibility patrols for the purpose of crime
prevention and suppression. On Januray 17, 2000, the IBP filed the instant petition to declare the
deployment of Philippines Marines unconstitutional thus null and void alleging that no emergency situation
would justify the employment of soldiers for law enforcement work and that the same is in derogation of
Article II Section 3 of the Constitution.
ISSUE:
Whether or not the joint visibility patrols violate the Constitutional provisions on civilian supremacy over
the military
HELD:
The calling of the Marines in this case constitutes permissible use of military assets for civilian
enforcement and that it does not contravene Section 3, Article II of the Constitution. The limited
participation of the Marines is evident in the LOI itself which sufficiently provides the metes and bounds of
the Marines authority. The deployment of the Marines to assist the PNP does not unmake the civilian
character of the police force. The real authority in these operations is lodged with the head of a civilian
institution and not with the military. What is in here is mutual support and cooperation between the military
and the civilian authorities, not derogation of civilian supremacy. Wherefore, the petition is hereby
dismissed.