s corpus by ruling that martial law was a political question beyond the jurisdiction of the court; and that, furthermore, the court had already deemed the 1973 Constitution in full force and effect, replacing the 1935 Constitution.
After the landmark decision, Chief Justice Roberto V. Concepcion went into early retirement, 50 days before his originally scheduled retirement date, in silent protest over the majority in the Javellana v. Executive Secretary case. He argued against the validity of the new constitution and its questionable aspects, together with Justices Claudio Teehankee, Calixto Zaldivar, and Enrique Fernando.
Martial law imposed government control over all forms of media. On September 22, 1972, Marcos issued Letter of Instruction No. 1, ordering the Press Secretary and Defense Secretary to assume control over all media outlets. All periodicals were padlocked,[7] and media personalities who had criticized Marcos, his family, or his administration were taken to Camp Crame without any charges being filed. Among them were publishers Joaquin “Chino” P. Roces (Manila Times) and Eugenio Lopez Jr. (Manila Chronicle), and columnists Max Soliven and Luis D. Beltran.[8]
Marcos issued at least eleven Presidential Decrees that suppressed press freedom. Journalists who did not comply with the new restrictions faced physical threats, libel suits, or forced resignation.[9] With such stringent censorship regulations, most of the periodicals that were allowed to operate were crony newspapers, such as Benjamin Romualdez’s Times Journal, Hans Menzi’s Bulletin Today, and Roberto Benedicto’s Philippine Daily Express. These newspapers offered “bootlicking reportage” on the country’s economy while completely eschewing political issues.[10]
Hence, President Marcos’ absolute rule had a “cloak of legality”[11] and incontestability, making it nearly impregnable. However, specific factors converged and eventually led to the fall of the dictatorship and the eventual restoration of democracy in the Philippines.
II. Factors that led to the Fall of the Dictatorship
A. Opposition to Martial Law in the 1970s
Popular anti-Marcos sentiment existed for the duration of Martial Law. According to David Wurfel, there were three paramount types of opposition to martial law during the 1970s: reformist opposition, revolutionary opposition, and religious opposition.[12]
Reformist Opposition
The reformist opposition, also known as the legal opposition, was composed of members of the upper-middle class. Using nonviolent tactics, they advocated political (not necessarily socioeconomic) reforms. However, the reformist opposition was not a united movement, but an amalgamation of different middle- and upper-class groups who had different motives. It was for this reason that Marcos tolerated them, so long as they were incapable of viably replacing him or attaining the support of the masses.[13] David Wurfel writes:
