Editing Manuel L. Quezon (section)

===First term (1935–1941)===
[[File:Manuel Quezon First Inauguration.jpg|alt=Quezon taking the oath of office|thumb|The First inauguration of Philippine Commonwealth President Manuel L. Quezon at the steps of the [[National Museum of Fine Arts (Manila)|Legislative Building]] in [[Manila]] on the 15th of November 1935]]In 1935, Quezon won the Philippines' [[1935 Philippine general election|first national presidential election]] under the [[Nacionalista Party]]. He received nearly 68 percent of the vote against his two main rivals, [[Emilio Aguinaldo]] and [[Gregorio Aglipay]]. Quezon, inaugurated on November 15, 1935,<ref>{{Cite web |date=November 15, 1935 |title=Inaugural Address of President Manuel L. Quezon, November 15, 1935 |url=https://www.officialgazette.gov.ph/1935/11/15/inaugural-address-of-president-quezon-november-15-1935/ |access-date=May 19, 2021 |publisher=Official Gazette of the Republic of the Philippines}}</ref> is recognized as the second [[President of the Philippines]]. In January 2008, however, House Representative Rodolfo Valencia ([[Oriental Mindoro]]–[[Oriental Mindoro's 1st congressional district|1st]]) filed a bill seeking to declare General [[Miguel Malvar]] the second Philippine President; Malvar succeeded Aguinaldo in 1901.<ref>{{Cite news |last=Cruz |first=Maricel |date=2 January 2008 |title=Lawmaker: History wrong on Gen. Malvar |url=http://www.manilatimes.net/national/2008/jan/02/yehey/top_stories/20080102top6.html |url-status=dead |access-date=2 May 2008 |archive-url=https://web.archive.org/web/20080406082026/http://www.manilatimes.net/national/2008/jan/02/yehey/top_stories/20080102top6.html |archive-date=6 April 2008}}</ref>

==== Supreme Court appointments ====
Under the Reorganization Act, Quezon was given the power to appoint the first all-Filipino cabinet in 1935. From 1901 to 1935, a Filipino was chief justice but most Supreme Court justices were Americans. Complete Filipinization was achieved with the establishment of the Commonwealth of the Philippines in 1935. Claro M. Recto and José P. Laurel were among Quezon's first appointees to replace the American justices. Membership in the Supreme Court increased to 11: a chief justice and ten associate justices, who sat ''en banc'' or in two divisions of five members each.

* [[Ramón Avanceña]]&nbsp;– 1935 ([[Chief Justice of the Philippines|Chief Justice]])&nbsp;– 1935–1941
* [[José Abad Santos]]&nbsp;– 1935
* [[Claro M. Recto]]&nbsp;– 1935–1936
* [[José P. Laurel]]&nbsp;– 1935
* [[José Abad Santos]] (Chief Justice)&nbsp;– 1941–1942

====Government reorganization====
[[Image:Quezon Staircase.jpg|thumb|President Manuel L. Quezon climbs up the grand staircase of Malacañan Palace with aide-de-camp Col. [[Manuel Nieto (born 1892)|Manuel Nieto]] and Presidential Guard Battalion Commander Col. Narciso Manzano.]]
To meet the demands of the newly-established government and comply with the [[Tydings-McDuffie Act]] and the [[Constitution of the Philippines|Constitution]], Quezon,{{snd}} true to his pledge of "more government and less politics,"{{snd}}initiated a reorganization of the [[Government of the Philippines|government]].<ref name="Molina, Antonio 1961">{{Cite book |last=Molina |first=Antonio M. |url={{GBurl|id=ZxFbAAAAIAAJ}} |title=The Philippines Through the Centuries |date=1961 |publisher=University of Santo Tomas Cooperative |edition=Print |location=Manila |language=en}}</ref> He established a Government Survey Board to study existing institutions and, in light of changed circumstances, make necessary recommendations.<ref name="Molina, Antonio 1961" />

Early results were seen with the revamping of the executive department; offices and bureaus were merged or abolished, and others were created.<ref name="Molina, Antonio 1961" /> Quezon ordered the transfer of the [[Philippine National Police|Philippine Constabulary]] from the [[Department of the Interior and Local Government|Department of the Interior]] to the [[Department of Finance (Philippines)|Department of Finance]]. Other changes were made to the [[Department of National Defense (Philippines)|National Defense]], [[Department of Agriculture (Philippines)|Agriculture]] and [[Department of Trade and Industry (Philippines)|Commerce]], [[Department of Public Works and Highways|Public Works]] and [[Department of Transportation (Philippines)|Communications]], and [[Department of Health (Philippines)|Health]] and [[Department of Social Welfare and Development|Public Welfare]] departments.<ref name="Molina, Antonio 1961" />

New offices and boards were created by executive order or legislation.<ref name="Molina, Antonio 1961" /> Among these were the [[National Security Council (Philippines)|Council of National Defense]],<ref name="GovPH-CA1">{{Cite web |title=Commonwealth Act No. 1 |url=https://www.officialgazette.gov.ph/1935/12/21/commonwealth-act-no-1/ |archive-url=https://web.archive.org/web/20181118081612/https://www.officialgazette.gov.ph/1935/12/21/commonwealth-act-no-1/ |archive-date=18 November 2018 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=21 December 1935 }}</ref> the [[National Disaster Risk Reduction and Management Council|Board of National Relief]],<ref name="GovPH-EO61">{{Cite web |title=Executive Order No. 61, s. 1936 |url=http://www.officialgazette.gov.ph/1936/11/03/executive-order-no-61-s-1936/ |archive-url=https://web.archive.org/web/20190325163146/http://www.officialgazette.gov.ph/1936/11/03/executive-order-no-61-s-1936/ |archive-date=25 March 2019 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=3 November 1936 }}</ref> the [[Department of Mindanao and Sulu|Mindanao and Sulu]] Commission, and the [[Civil Service Commission (Philippines)|Civil Service]] Board of Appeals.<ref name="Molina, Antonio 1961" /><ref name="GovPH-EO39">{{Cite web |title=Executive Order No. 39, s. 1936 |url=https://www.officialgazette.gov.ph/1936/06/23/executive-order-no-39-s-1936/ |archive-url=https://web.archive.org/web/20190325163556/https://www.officialgazette.gov.ph/1936/06/23/executive-order-no-39-s-1936/ |archive-date=25 March 2019 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=23 June 1936 }}</ref>
[[File:Manuel Quezon Inaugural Barong.jpg|alt=President Manuel L. Quezon wearing his Inaugural Barong|thumb|President Quezon wearing his Inaugural [[Barong tagalog|barong]]]]

===={{anchor|Social justice program}}Social-justice program====
Pledging to improve the conditions of the Philippine working class and inspired by the social doctrines of [[Pope Leo XIII]] and [[Pope Pius XI]] and treatises by the world's leading sociologists, Quezon began a program of [[social justice]] introduced with executive measures and legislation by the [[National Assembly of the Philippines|National Assembly]].<ref name="Molina, Antonio 1961" /> A court for industrial relations was established to mediate disputes, minimizing the impact of strikes and lockouts. A minimum-wage law was enacted, as well as a law providing an eight-hour workday and a tenancy law for Filipino farmers. The position of public defender was created to assist the poor.<ref name="Molina, Antonio 1961" />

Commonwealth Act No. 20 enabled Quezon to acquire large, occupied estates to re-appropriate their lots and homes at a nominal cost and under terms affordable by their residents; one example was the Buenavista estate. He also began a cooperative system of agriculture among owners of the subdivided estates to increase their income.<ref name="Molina, Antonio 1961" /><ref name="GovPH-CA20">{{Cite web |title=Commonwealth Act No. 20 |url=https://www.officialgazette.gov.ph/1936/07/11/commonwealth-act-no-20/ |archive-url=https://web.archive.org/web/20180324224537/https://www.officialgazette.gov.ph/1936/07/11/commonwealth-act-no-20/ |archive-date=24 March 2018 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=11 July 1936 }}</ref> Quezon desired to follow the constitutional mandate on the promotion of social justice.<ref name="Molina, Antonio 1961" />

====Economy====
[[File:President Manuel L. Quezon signed the budget.jpg|thumb|President Manuel L. Quezon signed the budget for the following year in 1937]]
When the Commonwealth was created, its economy was stable and promising.<ref name="Molina, Antonio 1961" /> With foreign trade peaking at {{Philippine peso|400&nbsp;million|link=yes}}, the upward trend in business resembled a boom. Export crops were generally good and, except for tobacco, were in high demand. The value of Philippine exports reached {{₱|320,896,000}}, the highest since 1929.<ref name="Molina, Antonio 1961" />
[[File:President Manuel L. Quezon at Work.jpg|thumb|President Quezon at work in The Executive Building (now [[Kalayaan Hall]])]]
[[File:President Manuel Quezon of Philippine Commonwealth broadcast from Washington today to his fellow-countrymen in Manila.jpg|alt=Quezon, writing at a desk behind a U.S. radio microphone|thumb|Quezon before a 1937 [[NBC]] broadcast]]

Government revenue in 1936 was {{Philippine peso|76,675,000|1936}}, compared to the 1935 revenue of {{Philippine peso|65,000,000|1935}}. Government companies, except for the [[Manila Railroad Company]], earned profits. Gold production increased about 37 percent, iron nearly doubled, and cement production increased by about 14 percent.<ref name="Molina, Antonio 1961" />

The government had to address some economic problems, however,<ref name="Molina, Antonio 1961" /> and the National Economic Council was created. It advised the government about economic and financial questions, including the promotion of industries, diversification of crops and enterprises, [[tariffs]], taxation, and formulating an economic program in preparation for eventual independence.<ref name="Molina, Antonio 1961" /> The National Development Company was reorganized by law, and the National Rice and Corn Company (NARIC) was created with a {{₱|4&nbsp;million}} budget.<ref name="Molina, Antonio 1961" />

Upon the recommendation of the National Economic Council, agricultural colonies were established in [[Koronadal]], Malig, and other locations in [[Mindanao]]. The government encouraged migration and settlement in the colonies.<ref name="Molina, Antonio 1961" /> The Agricultural and Industrial Bank was established to aid small farmers with convenient loans and affordable terms.<ref name="TheCorpusJuris-CA459">{{Cite web |date=9 June 1939 |title=C.A. No. 459: An Act Creating the Agricultural and Industrial Bank |url=https://thecorpusjuris.com/legislative/commonwealth-acts/ca-no-459.php |archive-url=https://web.archive.org/web/20180818035303/http://www.thecorpusjuris.com/legislative/commonwealth-acts/ca-no-459.php |archive-date=18 August 2018 |access-date=25 March 2019 |website=The Corpus Juris |language=en}}</ref> Attention was paid to soil surveying and the disposition of public land.<ref name="Molina, Antonio 1961" />

===={{anchor|Agrarian reform}}Land reform====
{{See also|Land reform in the Philippines}}

When the commonwealth government was established, Quezon implemented the Rice Share Tenancy Act of 1933 to regulate share-tenancy contracts by establishing minimum standards.<ref name="Manapat, Carlos 2010">{{cite book |last1=Manapat |first1=Carlos L. |title=Economics, Taxation, and Agrarian Reform |date=2010 |publisher=C & E Publishing, Incorporated |isbn=978-971-584-989-0 |url={{GBurl|id=XO27swEACAAJ}} |language=en |access-date=4 April 2023 }}</ref><ref name="ChanRobles-Act4054">{{Cite web |title=Act No. 4054 |url=http://www.chanrobles.com/acts/actsno4054.html |archive-url=https://web.archive.org/web/20180123102708/http://www.chanrobles.com/acts/actsno4054.html |archive-date=23 January 2018 |access-date=25 March 2019 |website=Chan Robles Virtual Law Library}}</ref> The act provided a better tenant-landlord relationship, a 50–50 sharing of the crop, regulation of interest at 10 percent per agricultural year, and protected against arbitrary dismissal by the landlord.<ref name="Manapat, Carlos 2010" /> Because of a major flaw in the act, however, no petition to apply it was ever presented.<ref name="Manapat, Carlos 2010" />

The flaw was that it could be used only when the majority of [[Sangguniang Bayan|municipal councils]] in a province petitioned for it.<ref name="Manapat, Carlos 2010" /> Since landowners usually controlled such councils, no province ever asked that the law be applied. Quezon ordered that the act be mandatory in all [[Central Luzon]] provinces.<ref name="Manapat, Carlos 2010" /> However, contracts were good for only one year; by refusing to renew their contract, landlords could eject tenants. Peasant organizations clamored in vain for a law which would make a contract automatically renewable as long as tenants fulfilled their obligations.<ref name="Manapat, Carlos 2010" /> The act was amended to eliminate this loophole in 1936, but it was never carried out; by 1939, thousands of peasants in Central Luzon were threatened with eviction.<ref name="Manapat, Carlos 2010" /> Quezon's desire to placate both landlords and tenants pleased neither. Thousands of tenants in Central Luzon were evicted from their farmlands by the early 1940s, and the rural conflict was more acute than ever.<ref name="Manapat, Carlos 2010" />

During the Commonwealth period, agrarian problems persisted.<ref name="Manapat, Carlos 2010" /> This motivated the government to incorporate a social-justice principle into the [[Constitution of the Philippines#The 1935 Constitution|1935 Constitution]]. Dictated by the government's social-justice program, expropriation of estates and other landholdings began. The National Land Settlement Administration (NLSA) began an orderly settlement of public agricultural lands. At the outbreak of the Second World War, settlement areas covering over {{convert|65,000|ha|sqmi}} had been established.<ref name="Manapat, Carlos 2010" />

====Educational reforms====
With his Executive Order No. 19, dated 19 February 1936, Quezon created the National Council of Education. [[Rafael Palma]], former president of the [[University of the Philippines]], was its first chairman.<ref name="Molina, Antonio 1961" /><ref name="GovPH-EO19">{{Cite web |title=Executive Order No. 19, s. 1936 |url=https://www.officialgazette.gov.ph/1936/02/19/executive-order-no-19-s-1936/ |archive-url=https://web.archive.org/web/20190325154725/https://www.officialgazette.gov.ph/1936/02/19/executive-order-no-19-s-1936/ |archive-date=25 March 2019 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=19 February 1936 }}</ref> Funds from the early Residence Certificate Law were devoted to maintaining public schools throughout the country and opening many more. There were 6,511 primary schools, 1,039 intermediate schools, 133 secondary and special schools, and five junior colleges by this time. Total enrollment was 1,262,353, with 28,485 teachers. The 1936 appropriation was {{Philippine peso|14,566,850|1936}}.<ref name="Molina, Antonio 1961" /> Private schools taught over 97,000 students, and the Office of Adult Education was created.<ref name="Molina, Antonio 1961" />

====Women's suffrage====
[[File:President Quezon signing the Women’s Suffrage Bill.jpg|thumb|alt=Quezon signing the Women's Suffrage Bill in front of a large group of people|Quezon signing the Women's Suffrage Bill after the 1937 plebiscite]]
[[File:Philippine President Manuel Quezon broadcasts to home folks.jpg|alt=Quezon speaking into two NBC microphones|thumb|Quezon during a 25-minute broadcast to Manila from [[Washington, D.C.]], on 5 April 1937. He discussed women's suffrage and urged that the 10-year independence program be shortened.]]
Quezon initiated [[women's suffrage]] during the [[Commonwealth of the Philippines#Pre-War|Commonwealth era]].<ref name="ReferenceA">{{Cite book |last=Molina |first=Antonio |title=The Philippines: Through the centuries |publisher=University of Santo Tomas Cooperative |year=1961 |edition=Print}}</ref> As a result of prolonged debate between proponents and opponents of women's suffrage, the constitution provided that the issue be resolved by women in a [[1937 Philippine women's suffrage plebiscite|plebiscite]]. If at least 300,000 women voted for the right to vote, it would be granted. The plebiscite was held on 30 April 1937; there were 447,725 affirmative votes, and 44,307 opposition votes.<ref name="ReferenceA" />

====National language====
The Philippines' national language was another constitutional question. After a one-year study, the [[Commission on the Filipino Language|Institute of National Language]] recommended that [[Tagalog language|Tagalog]] be the basis for a national language. The proposal was well-received, despite the fact that director [[Jaime C. de Veyra]] was [[Waray people|Waray]], this is because Baler, Quezon's birthplace, is a native Tagalog-speaking area.

In December 1937, Quezon issued a proclamation approving the institute's recommendation and declaring that the national language would become effective in two years. With presidential approval, the INL began work on a Tagalog grammar text and dictionary.<ref name="ReferenceA" />

====Visits to Japan (1937–1938)====
As [[Empire of Japan|Imperial Japan]] encroached on the Philippines, Quezon antagonized neither the American nor the Japanese officials. He travelled twice to Japan as president, from 31 January to 2 February 1937 and from 29 June to 10 July 1938, to meet with government officials. Quezon emphasized that he would remain loyal to the [[United States]], assuring protection of the rights of the Japanese who resided in the Philippines. Quezon's visits may have signalled the Philippines' inclination to remain neutral in the event of a Japanese-American conflict if the U.S. disregarded the country's concerns.<ref>{{Cite book |last=Yu-Jose |first=Lydia |title=''Philippine-Japan Relations: the Revolutionary Years and a Century Hence'' in Philippine External Relations: A Centennial Vista |publisher=Foreign Service Institute |year=1998}}</ref>

===={{anchor|Council of State}}Council of State expansion====
In 1938, Quezon expanded the [[Council of State (Philippines)|Council of State]] in Executive Order No. 144.<ref name="ReferenceA" /><ref name="GovPH-EO144">{{Cite web |title=Executive Order No. 144, s. 1938 |url=http://www.officialgazette.gov.ph/1938/03/17/executive-order-no-144-s-1938/ |archive-url=https://web.archive.org/web/20190325161109/http://www.officialgazette.gov.ph/1938/03/17/executive-order-no-144-s-1938/ |archive-date=25 March 2019 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=17 March 1938 }}</ref> This highest of advisory bodies to the president would be composed of the President, [[Vice President of the Philippines|Vice President]], [[President of the Senate of the Philippines|Senate President]], [[Speaker of the House of Representatives of the Philippines|House Speaker]], [[President pro tempore of the Senate of the Philippines|Senate President pro tempore]], [[House of Representatives of the Philippines#Speaker pro tempore|House Speaker pro tempore]], the majority floor leaders of both chambers of [[Congress of the Philippines|Congress]], former presidents, and three to five prominent citizens.<ref name="ReferenceA" />

====1938 midterm election====
{{main|1938 Philippine legislative election}}

The elections for the Second National Assembly were held on 8 November 1938 under a new law which allowed [[Plurality block voting|block voting]]<ref>{{Cite news |title=Block voting |newspaper=Philippine Daily Inquirer |url=http://opinion.inquirer.net/inquireropinion/columns/view_article.php?article_id=33603 |access-date=10 September 2012}}{{dead link|date=December 2017 |bot=InternetArchiveBot |fix-attempted=yes }}</ref> and favored the governing [[Nacionalista Party]]. As expected, all 98 assembly seats went to the Nacionalistas. [[José Yulo]], Quezon's [[Department of Justice (Philippines)#List of Secretaries of Justice|Secretary of Justice]] from 1934 to 1938, was elected speaker.

The [[2nd National Assembly of the Philippines|Second National Assembly]] intended to pass legislation strengthening the economy, but the Second World War clouded the horizon; laws passed by the First National Assembly were modified or repealed to meet existing realities.<ref>Commonwealth Act (CA) No. 494 amended CA 444, the "Eight Hour Law", authorizing the president to suspend it.</ref><ref name="TheCorpusJuris-CA494">{{Cite web |date=30 September 1939 |title=C.A. No. 494: An Act to Authorize the President of the Philippines to Suspend, Until We Date of Adjournment of the Next Regular Session of the National Assembly Either Wholly or Partially the Operation of Commonwealth Act Numbered Four Hundred and Forty-Four, Commonly Known as the Eight-Hour Labor Law |url=https://thecorpusjuris.com/legislative/commonwealth-acts/ca-no-494.php |archive-url=https://web.archive.org/web/20190325160117/https://thecorpusjuris.com/legislative/commonwealth-acts/ca-no-494.php |archive-date=25 March 2019 |access-date=25 March 2019 |website=The Corpus Juris |language=en}}</ref> A controversial [[immigration law]] which set an annual limit of 50 immigrants per country,<ref name="ChanRobles-CA613">{{Cite web |title=Commonwealth Act No. 613 |url=http://www.chanrobles.com/commonwealthactno613.htm |archive-url=https://web.archive.org/web/20181210113308/http://www.chanrobles.com/commonwealthactno613.htm |archive-date=10 December 2018 |access-date=25 March 2019 |website=Chan Robles Virtual Law Library}}</ref> primarily affecting Chinese and Japanese nationals escaping the [[Second Sino-Japanese War|Sino-Japanese War]], was passed in 1940. Since the law affected foreign relations, it required the approval of the U.S. president. When the 1939 [[Demographics of the Philippines|census]] was published, the National Assembly updated the apportionment of legislative districts; this became the basis for the [[1941 Philippine general election|1941 elections]].

====1939 plebiscite====
On 7 August 1939, the [[United States Congress]] enacted a law in accordance with the recommendations of the Joint Preparatory Commission on Philippine Affairs. Because the new law required an amendment of the Ordinance appended to the Constitution, a plebiscite was held on 24 August 1939. The amendment received 1,339,453 votes in favor, and 49,633 against.<ref name="ReferenceA" />

====Third official language====
[[File:President Manuel L. Quezon signing Executive Order No. 134.jpg|alt=President Manuel L. Quezon signing Executive Order No. 134.|thumb|Quezon signs [https://www.officialgazette.gov.ph/1937/12/30/executive-order-no-134-s-1937/ Executive Order No. 134.]]]
Quezon had established the Institute of National Language (INL) to create a national language for the country. On 30 December 1937, in [https://www.officialgazette.gov.ph/1937/12/30/executive-order-no-134-s-1937/ Executive Order No. 134], he declared [[Tagalog language|Tagalog]] the Philippines' national language; it was taught in schools during the 1940–1941 academic year. The National Assembly later enacted Law No. 570, making the [[Filipino language|national language]] an official language with English and Spanish; this became effective on 4 July 1946, with the establishment of the Philippine Republic.<ref name="ReferenceA" /><ref name="GovPH-EO134">{{Cite web |title=Executive Order No. 134, s. 1937 |url=http://www.officialgazette.gov.ph/1937/12/30/executive-order-no-134-s-1937/ |archive-url=https://web.archive.org/web/20180814205508/http://www.officialgazette.gov.ph/1937/12/30/executive-order-no-134-s-1937/ |archive-date=14 August 2018 |access-date=25 March 2019 |website=Official Gazette of the Republic of the Philippines|date=30 December 1937 }}</ref>

===={{anchor|1940 plebiscite}}1940 plebiscites====
{{main|1940 Philippine constitutional plebiscites}}

With the 1940 local elections, plebiscites were held for proposed amendments to the constitution about a bicameral legislature, the presidential term (four years, with one re-election, and the establishment of an independent [[Commission on Elections (Philippines)|Commission on Elections]]. The amendments were overwhelmingly ratified. Speaker José Yulo and Assemblyman Dominador Tan traveled to the United States to obtain President [[Franklin D. Roosevelt]]'s approval, which they received on 2 December 1940. Two days later, Quezon proclaimed the amendments.

====1941 presidential election====

Quezon was originally barred by the Philippine constitution from seeking re-election. In 1940, however, a constitutional amendment was ratified which allowed him to serve a second term ending in 1943. In the [[1941 Philippine general election|1941 presidential election]], Quezon was re-elected over former [[Senate of the Philippines|Senator]] [[Juan Sumulong]] with nearly 82 percent of the vote. He was inaugurated on December 30, 1941 at the [[Malinta Tunnel]] in [[Corregidor]].<ref>{{Cite speech |date=December 30, 1941 |title=Second Inaugural Address of President Quezon |url=https://www.officialgazette.gov.ph/1941/12/30/second-inaugural-address-of-president-quezon/ |access-date=May 19, 2021 |publisher=Official Gazette of the Republic of the Philippines}}</ref> The oath of office was administered by [[Chief Justice of the Supreme Court of the Philippines]] [[José Abad Santos]]. Corregidor was chosen as the venue of the inauguration and temporary seat of the government [[Government in exile of the Commonwealth of the Philippines|in-exile]] to take refuge from the uninterrupted Japanese bombing raids during the [[Philippines campaign (1941–1942)|Japanese invasion]].<ref>{{cite web |title=Jose Abad Santos |url=https://www.officialgazette.gov.ph/about/gov/judiciary/sc/cj/jose-abad-santos/ |accessdate=June 6, 2023 |publisher=Official Gazette of the Republic of the Philippines}}</ref>