Chief Justice Concepcion took a leave 18 days after the decision became public (50 days from his scheduled retirement) supposedly because he was disappointed on the outcome of the decision. He would later become a member of the Philippine Constitutional Commission of 1986 that drafted the 1987 Philippine Constitution. Drawing from his experiences in the martial law years, he introduced several innovations designed to assure the independence of the Supreme Court, such as the Judicial and Bar Council and the express conferment on the Court the power to review any acts of government.