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It is evident that the Philippine Executive Commission which was organized by the
Order No 1, issued by the Commander of the Japanese forces was a civil
government established by the military forces of occupation and therefore a de
facto government of the 2nd kind.
It necessarily follows that the judicial acts and proceedings of the courts of justice of
those governments which are not of a political complexion, were good and valid,
and by virtue of the well known principle of postliminy in international law,
remained good and valid after the liberation and reoccupation of the Philippines by
the American and Filipino forces under the leadership of Mac Arthur.
Dissent by Perfecto J. Douglas MacArthur as commander in chief of an army is
vested with extraordinary inherent powers, as a natural result of the nature of the
military operations aimed to achieve the purposes of his country in the war, victory
being paramount among them. OCTOBER PROCLAMATION CANNOT BE CHALLENGED