section_path: Title/Historical titles
section_name: Historical titles
paragraph_text: Historical titles
  
  The term "President of the Republic of the Philippines" used under Japanese occupation of the Philippines distinguished the government of then-president José P. Laurel from the Commonwealth government-in-exile under President Manuel L. Quezon. The restoration of the Commonwealth in 1945 and the subsequent independence of the Philippines restored the title of "President of the Philippines" enacted in the 1935 constitution. The 1973 constitution, though generally referring to the president as "President of the Philippines", Article XVII, Section 12 once used the term, "President of the Republic." In the text of Proclamation No. 1081 that placed the country under martial law in September 1972, President Ferdinand Marcos consistently referred to himself as "President of the Philippines."