(1964)). Legacy The Court was divided upon the decision, having a vote of 6-4 (one justice died a month before its promulgation). But it was later on accepted as valuable jurisprudence, starting with the subsequent case of People of the Philippines v. Geronimo (100 Phil. Reports 90). The case is now a standard case study in Philippine law schools. According to Justice J.B.L. Reyes, during the deliberations of the Hernandez case, Justice Sabino Padilla (who is the brother of the Solicitor General, Ambrosio Padilla) openly accused Chief Justice Ricardo Paras for being prejudiced against the Government and asking biased questions during the oral argument. Riled, Paras rebutted, and a heated exchange soon ensued between the Chief Justice and Padilla, which would have worsened had not they restrained themselves. As of 1990, the Philippine Supreme Court again revisited the doctrine in Hernandez, where Juan Ponce Enrile was similarly charged with the same offense as Hernandez. The Supreme Court upheld anew the Hernandez decision (Enrile v. Salazar (1990)), maintaining that it is still good law and applicable. References Agoncillo, Teodoro A. (1990). History of the Filipino People (8th edition). Garotech Publishing, Quezon City Cruz, Isagani A. (2000). Res Gestae: A Brief History of the Supreme Court. Rex Book Store, Manila Reyes, Luis B. (2001). The Revised Penal Code: Criminal Law, Vol. 2. Rex Book Store, Manila People v. Hernandez 1956 in case law 1956 in the Philippines Communism in the Philippines Rebellions in the Philippines