CO KIM CHAM v. EUSEBIO VALDEZ TAN KEH and ARSENIO P.

DIZON
G.R. No. L-5, September 17, 1945

FACTS
Co Kim Cham had a pending civil case initiated during the Japanese occupation with the
CFI of Manila. After the liberation of the Manila and the American occupation, respondent Judge
Dizon refused to continue hearings, saying that a proclamation issued by General Douglas
MacArthur had invalidated and nullified all judicial proceedings and judgments of the courts of
the defunct Republic of the Philippines.

ISSUES
Whether or not the judicial acts and proceedings made under Japanese occupation were valid and
remained valid even after the American occupation.

RULING
All acts and proceedings of the legislative, executive, and judicial departments of a de
facto government are good and valid. If [the governments established in these Islands under the
names of the Philippine Executive Commission and Republic of the Philippines during the
Japanese military occupation or regime were de facto governments], the judicial acts and
proceedings of those governments remain good and valid even after the liberation or
reoccupation of the Philippines by the American and Filipino forces.

The governments by the Philippine Executive Commission and the Republic of the
Philippines during the Japanese military occupation being de facto governments, it necessarily
follows that the judicial acts and proceedings of the courts of justice of those governments,
which are not of a political complexion, were good and valid, and, by virtue of the well-known
principle of postliminy in international law, remained good and valid after the liberation or
reoccupation of the Philippines by the American and Filipino forces under the leadership of
General Douglas MacArthur.