He would later become a member of the Philippine Constitutional Commission of 1986 that drafted the 1987 Philippine Constitution. Drawing from his experiences in the martial law years, he introduced several innovations designed to assure the independence of the Supreme Court, such as the Judicial and Bar Council and the express conferment on the Court the power to review any acts of government. In The Conjugal Dictatorship of Ferdinand and Imelda Marcos, it was observed by Primitivo Mijares in the Chapter "Spineless Judiciary: Legitimizing A Pretender" that, while the Ratification Cases was resolved in a matter of months, the other cases involving Marcos’ imprisoned critics were not decided until a year or two later. In fact, some of the critics withdraw their petitions, mostly for writ of habeas corpus, due to the lack of confidence that the Supreme Court would grant their relief. Makalintal, when he became Chief Justice, also took a similar approach of Concepcion in deciding the case of the Habeas Corpus Cases of Benigno Aquino Jr. () by summarizing the diverse votes of the members of the court. He explained the reason why there was no collegial opinion by the Court, among others, that the justices of the Supreme Court are conscious of "the future verdict of history". At the time of Chief Justices Castro and Fernando, the Supreme Court, using the ‘legitimizing’ power, affirmed the legality of the Ratification Cases through several cases, such as Sanidad v. COMELEC (1976) and Occena v. COMELEC (1981). Of the four justices who voted to grant relief, Concepcion and Calixto Zaldivar left the court due to retirement. Justices Teehankee, first identified with the regime, began to show his independence by consistently dissenting on several decisions made by the court. He was accompanied in such dissents by Justice Cecilia Muñoz-Palma, and later, by Vicente Abad Santos. Fernando, though expected that he would be one to oppose the excesses of the Marcos's regime, became its supporter. Legacy The decision in the Ratification Cases are still studied by students of Philippine Law with respect to the proper ratification and approval of a new Constitution. It also gave a lesson and reminder of the Marcos regime and its effects to the Filipino people. It also shows that the Supreme Court are composed of human beings susceptible of error, in the words of Justice Isagani Cruz, "...is not an ivory tower occupied by demigods but