The Ratification Cases, officially titled as Javellana v. Executive Secretary (G.R. No. L-36142, March 31, 1973; 50 SCRA 30), was a 1973 Supreme Court of the Philippines case that allowed the 1973 Philippine Constitution to come into full force, which led to President Ferdinand Marcos staying in power and ruling by decree until he was ousted by the People Power Revolution in 1986. The decision became the cornerstone of subsequent decisions whenever the validity of the 1973 Constitution was questioned. Background Marcos declared martial law on September 21, 1972. The Congress of the Philippines was then padlocked, and full legislative authority was vested on Marcos who ruled by decree. Many prominent members of the opposition, notably Benigno Aquino Jr. and Jose W. Diokno, were arrested and placed in military jails. Despite the declaration of martial law, the 1971 Constitutional Convention continued. On November 29, 1972, the Convention approved the new constitution and the next day, Marcos issued Presidential Decree 73, "Submitting to the Filipino people, for ratification or rejection, the Constitution of the Republic of the Philippines proposed by the 1971 Constitutional Convention, and appropriating funds therefor", as well as setting the plebiscite for ratification on January 15, 1973. Charito Planas, a staunch critic and later vice-mayor of Quezon City, filed a case, known as the Plebiscite Cases (Planas v. COMELEC (1973)) before with the Supreme Court calling for a stop to the proposed ratification upon the grounds, among others, that the Presidential Decree "has no force and effect as law because the calling... of such plebiscite, the setting of guidelines for the conduct of the same, the prescription of the ballots to be used and the question to be answered by the voters, and the appropriation of public funds for the purpose, are, by the Constitution, lodged exclusively in Congress..." and "there is no proper submission to the people there being no freedom of speech, press and assembly, and there being no sufficient time to inform the people of the contents thereof." On January 15, 1973, while the Plebiscite Cases were being heard in the Supreme Court, the president signed Proclamation 1102, which states that the 1973 Constitution was "ratified by an overwhelming majority of all the votes cast by the members of all the barangays (citizens' assemblies) throughout the Philippines..." during the 1973 constitutional plebiscite. By virtue of that decree, the Supreme Court dismissed the case for being