 For a time, Teehankee and Justice Cecilia Muñoz-Palma would dissent together.After Muñoz-Palma's retirement, he was joined by Associate Justice Vicente Abad Santos in dissenting.It was this activism that made Marcos 'by-pass' him twice for the position of Chief Justice (the most senior associate justice is most likely to succeed after the retirement of the Chief Justice) in 1985.