J. B. L. Reyes

Jose Benedicto Luis Luna Reyes (August 19, 1902 – December 27, 1994) was a Filipino jurist who served as an Associate Justice of the Supreme Court from 1954 to 1972.

After his retirement, Reyes became the first president of the Integrated Bar of the Philippines (IBP).

He also worked with José W. Diokno in groups such as the Free Legal Assistance Group (FLAG) and the Anti-Bases Coalition.

He was also a highly regarded legal scholar in the field of civil law.

Reyes was born in Manila to Dr. Ricardo Albino Reyes and Marcia Concepcion Luna.

By the age of 15, he had earned his Bachelor of Arts degree, magna cum laude, at the Ateneo de Manila University.

He was not allowed admission to the Philippine Bar until the following year, when he reached his 21st birthday.

Reyes would later pursue masteral and doctoral studies in law at the Complutense University of Madrid and the University of Santo Tomas.

He obtained his law degree from the University of the Philippines in 1922, and passed the bar examinations of that year, placing 6th.

In the 1930s, Reyes was a law professor at the University of the Philippines and at the Far Eastern University.

As early as then, he was earning esteem in the legal academe, and even abroad, particularly in the field of civil law.

His Dean at the U.P. College of Law, Jorge Bocobo, remarked that Reyes was among of two Filipinos rated as outstanding civilists in Spain.

Reyes weaved his strong nationalist views to an interpretation of the 1935 Constitution that emphasized its nationalistic thrust.

As a private practitioner, Reyes was among the founders of the Civil Liberties Union in 1937.

His association with that group helped foster his lifelong reputation as a civil libertarian and an ardent nationalist.

Within weeks after the Japanese invasion in 1941, Reyes helped organize the underground Free Philippines movement.

His involvement with the resistance was soon exposed, and he was imprisoned by the Japanese in Fort Santiago in 1944.

Unlike some of the other founders of the Free Philippines movement, such as Rafael Roces, Jr. and Antonio Bautista, Reyes was spared execution, though not torture.

After the war, Reyes was appointed to the Court of Appeals.

He also helped found in 1947 the Manuel L. Quezon University, and joined its law faculty.

When the Civil Code was enacted, Reyes, who had briefly served on the Code Commission before the war, published widely read article outlining his criticisms of several articles.

That article has since been cited favorably in a number of Supreme Court decisions.

After nine years with the Court of Appeals, Reyes was appointed to the Supreme Court in 1954 by President Ramon Magsaysay.

At 52, he was among the youngest justices appointed to the Court.

However, Reyes would never get to serve as Chief Justice.

This was in part because his close friend Roberto Concepcion, several months his junior, was appointed to the Court a few months before Reyes.

His dissenting opinion in Exconde v. Capuno, 101 Phil. 843 (1957), on the tort liability of schools for damages caused by their students, was eventually adopted by the Court in Amadora v. Court of Appeals, 160 SCRA 315 (1988).

Concepcion was named Chief Justice in 1966.

During his tenure on the Court, Reyes and Claro M. Recto were unsuccessfully nominated to the International Court of Justice.

In his 18 years on the Court, Reyes grew in prominence unlike few other Supreme Court magistrates before and since.

Often, especially on matters relating to his specialty, civil law, his opinions proved to be the final word.

In some quarters, he was called "the Court", in tribute to the considerable influence he wielded over his colleagues.

As expected, Reyes penned many leading decisions in civil law that remain widely studied today, including Tenchavez v. Escaño, 122 Phil. 765 (1966), on the recognition of foreign divorces in the Philippines; Republic v. Luzon Stevedoring, 128 Phil. 313 (1967), which defined force majeure; and Medina v. Makabali, 137 Phil. 329 (1969), affirming the best interest of the child as the paramount rule in custody cases.

He notably dissented in Moy Ya Lim Yao v. Commissioner of Immigration, 41 SCRA 292 (1971), where the Court had relaxed the requisites for a foreigner to acquire Filipino citizenship through marriage.

Reyes opined that unlike perhaps in the United States, the Philippine constitution disfavored the absorption of immigrants and thus the citizenship laws should be interpreted with that view in mind.

Upon his retirement in 1972, one of his colleagues, the future Chief Justice Felix Makasiar, said of Reyes that "[n]o jurist within living memory has commanded during the last quarter of a century, the deep respect and admiration of the bench and bar, of dilettantes and scholars, of professors and students."

In similar fashion was Reyes's most famous opinion, among his last, in Republic v. Quasha, 46 SCRA 160(1972).

The Court, through Reyes, insisted on a restrictive interpretation of the expiring Parity Amendments occasioned by the Bell Trade Act, towards the end of prohibiting the ownership by foreigners of residential lands.

At the end of his opinion, he criticized the earlier enactment of the Parity Amendments to the Constitution, saying:

That Filipinos should be placed under the so-called Parity in a more disadvantageous position than United States citizens in the disposition, exploitation, development and utilization of the public lands, forests, mines, oils and other natural resources of their own country is certainly rank injustice and inequity that warrants a most strict interpretation of the "Parity Amendment", in order that the dishonorable inferiority in which Filipinos find themselves at present in the land of their ancestors should not be prolonged more than is absolutely necessary.