However, the resistance in this case must be commensurate to the excess and "should not be greater than what is necessary to repel the aggression". Otherwise, it may still constitute a violation of either Article 148 or 151 of the Revised Penal Code. Furthermore, and as explained in Gallego vs. People, G.R. No. L-18247, 31 August 1963, the illegality of the order or the "excessiveness" of the actions must be manifest, otherwise disobedience is not justified.
Applying the foregoing in the context of the ECQ, it is clear that violations of orders of the police or law enforcement agents manning our checkpoints as well as those officers enforcing the city-wide curfews may constitute an offense under Article 151 of the RPC. If a person is arrested based on this offense, it will be incumbent upon him or her to show that he/she is not covered by the curfew or, at the very least, have justifiable reasons for violating them.