[1] While it was decided on an almost divided opinion, it nevertheless became a stable doctrine in Philippine jurisprudence It was the height of the Government action against communists and the Hukbalahap guerillas.

Writer (and future National Artist for Literature) Amado V. Hernandez, himself a labor leader, was arrested on January 26 for various rebellious activities with the CLO.

The government, headed by Solicitor General Ambrosio Padilla, argued that the gravity of the crime committed required the denial of the bail.

Moreover, the complex crime charged by the government against Hernandez has been successfully imposed with other arrested communist leaders and was sentenced to life imprisonment.

The Supreme Court upheld anew the Hernandez decision (Enrile v. Salazar (1990)), maintaining that it is still good law and applicable.