"With due respect to my colleagues, I cannot join them in their acceptance of the President's categorization of the events in Marawi as equivalent to the rebellion mentioned in article VII section 18. In conscience I do not see the situation as providing for the kind of necessity for the imposition of Martial Law in Marawi as well as throughout the entire Philippines.
Rather, I read the situation as amounting to acts of terrorism which should be addressed in a decisive but more precise manner. The military can quell the violence. It can disrupt many of the planned atrocities that may yet to come. It can do so as it had on many occasions in the past with the current legal arsenal that it has." Leonen, J, dissenting. 2017 Mindanao Martial Law Cases