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obtained by force or voice of the majority, (2)


paramount force – by military forces who invade the
territory and (3) independent government –
established by inhabitants through insurrection.

Here, Laurel’s government is one by paramount force


while Quezon’s government is one by independent
government.

Hence, the acts of made by the Laurel government,


as a de facto government by paramount force, are
valid.  

 
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