Certainly not a paper force.
At least 50,000 marched out of Bataan to Capas, probably more.
About half died in Capas. My granduncle among them.
Those were the survivors of the campaign, who had not deserted to that point. There must have been at least 70,000 mobilized, that showed up for mobilization, in Luzon alone.
Add in whats known of the various units in Mindanao, Cebu, Panay, and the Philippine Army was indeed a substantial force, in numbers anyway.
What size was it in July 1941? IIRC, the bulk of the force you cite circa 12/41 were fresh conscripts.