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President Lacuesta proclaims martial law nationwide for 60 days in response to a violent coup attempt. On day 61, with Congress in recess and unable to act, Lacuesta issues a separate proclamation extending martial law for 18 days, limited to Mindanao, by executive order. A journalist detained under martial law challenges the extension as unconstitutional. (a) State the controlling rule on extensions beyond the initial 60 days and the role of Congress in extending or revoking martial law. (b) Apply the rule to the facts: is the 18-day unilateral extension valid? Explain. (c) If, subsequently, Congress enacts a joint resolution extending martial law nationwide for 30 additional days, explain the effect of that law on the previously declared extension and on the detainee’s status.

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