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His succession was codified in the Constitution of 1857 however he survived in internal exile for a period during which he signed the McLane-Ocampo Treaty in 1859. When reasonable liberal President Ignacio Comonfort was compelled to resign by the Conservatives in 1858, Juárez, as head of the Supreme Court, assumed the presidency and the two governments competed. His five-term governance only came to an end when he died of a coronary heart assault in 1872, making him the one Mexican president to die in workplace of a non-violent trigger.

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