112 Chasing the Wind: Assessing Philippine Democracy delete the required concurrence of the majority of the members of Congress because in the case of actual invasion or rebellion, the President might be hindered in effectively dealing with the crisis. This proposal was eventually approved, in spite of a significant number of commissioners who opposed it. Among those who opposed the proposal was the President of the Commission, former Justice Munoz Palma. She said: I am voting no because this has been a promise that I had personally made during the time of the Marcos regime, the promise to the people that if ever the Opposition comes to power, this will be one of the things that we will do; that is to limit the power of the President in suspending the privilege of the writ of habeas corpus and declaring martial law. (Records of the Constitutional Commission, vol. 2 1986: 486) After the decision not to require the concurrence of the majority of the members of Congress for suspending the writ of habeas corpus and the proclamation of martial law, the interpretation of “majority of the members of Congress” required for their revocation was discussed by the Commission. It turns out that the reference to “Congress” in this stipulation, the Commission referred to a unicameral congress. However, after this proposed provision was approved, the Commission modified the structure of congress and made it bicameral—250 members of the House of Representatives elected by districts and 24 senators elected nationally. In view of this change, Commissioner Monsod proposed the amendment, to wit: “The Congress, by a vote of at least a majority of all its members VOTING JOINTLY shall revoke” (Records of the Constitutional Commission, vol. 2, 1986, 497). The reason offered for this amendment is that since the concurrence of Congress is no longer required for the suspension of the writ of habeas corpus and the proclamation of martial law, its revocation should be vested with Congress in joint session. The Commissioners who opposed the amendment argued that the two chambers might disagree on their assessment about the factual bases of the Presidential action which would lead to gridlock and virtually allow the President to continue with martial law unchecked. The revised provision of the 1987 Constitution is noteworthy. It has addressed directly the unchecked power of the President to suspend the writ of habeas corpus and proclaim martial law. The Constitution itself limits the power of the President and protects Congress from being abolished. The Constitution also empowers the Supreme Court to review the factual basis of the proclamation of martial law or the suspension of the privilege of the writ of habeas corpus. The other limitations of this power apply to the observance of the privilege of the writ of habeas corpus in spite of its suspension (1987 Constitution of the Philippines, Article VII, Section 18).