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REPUBLIC OF THE PHILIPPINES

SUPREME COURT

En Banc, Manila

SUZETTE NICOLAS y SOMBILON,

Petitioner,

- versus- G.R. No. 175888

ALBERTO ROMULO, IN HIS

CAPACITY AS SECRETARY OF

FOREIGN AFFAIRS, ET. AL.,

Respondents.x-----------------------------------------------x

JOVITO R. SALONGA, ET. AL.,

Petitioners,

-versus- G.R. No. 176051

DANIEL SMITH, ET. AL.,

Respondents.

x-----------------------------------------------x

BAGONG ALYANSANG MAKABAYAN,ET. AL.,

Petitioners,

-versus- G.R. No. 176222

PRESIDENT GLORIA MACAPAGAL-

ARROYO, ET. AL.,

Respondents.

x----------------------------------------------x

MOTION FOR EXECUTION

Petitioners, through undersigned counsel, and to this Honorable

Court, respectfully state that:

1. In his dissent to the Majority Opinion that decided this case,

Associate Justice Antonio Carpio harkened back to thesensitivity of the framers of the Philippine Constitution to the

“unacceptable asymmetry” of the then existing United States

military bases in the Philippines.

2. In his dissent, Justice Carpio categorically stated:

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It would be naïve and foolish for the Philippines, or for

any other State for that matter, to implement as part of

its domestic law a treaty that the United States does not

recognize as part of its domestic law.

3. Unfortunately, recent events have proven the eminent Justice

correct in his assessment. Now, it is with one of our greatest

treasures that we are paying the price for such naivety and

foolishness.

4. Judgment was rendered by this Honorable Court on 11

February 2009, on the multiple Petitions filed before it seeking

the nullification of the Visiting Forces Agreement as well as theKenney-Romulo Agreements of December 19 and December

22 of 2009.

5. The dispositive portion of the aforementioned judgment

states:

WHEREFORE, the petitions are PARTLY GRANTED, AND

THE Court of Appeals’ Decision in CA-G.R. SP No. 97212

dated January 2, 2007 is MODIFIED. The Visiting ForcesAgreement (VFA) between the Republic of the

Philippines and the United States, entered into on

February 10, 1998, is UPHELD as constitutional, but the

Romulo-Kenney Agreements of December 19 and 22,

2006 are DECLARED not in accordance with the VFA,

and respondent Secretary of Foreign Affairs, is hereby

ordered to forthwith negotiate with the United States

representatives for the appropriate agreement on

detention facilities under Philippine authorities asprovided in Art. V, Sec. 10 of the VFA, pending which the

status quo shall be maintained until further orders by

this Court.

6. On 25 August 2009 and 28 August 2009, a Motion for

Reconsideration and Supplemental Motion for Reconsideration

were filed respectively by the Petitioners in GR No. 176051 and

196222.

7. Both Motions were Denied by this Honorable Court with

Finality on 12 January 2010.

8. Notice of the Court’s denial was received by Petitioner on 22

February 2010.

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9. From that period of time, no other Motions were filed by

either party within their reglementary period, hence the

original decision dated 11 February 2009 has become final andexecutory.

10. Judgment on this case notwithstanding, there has been little

effort exerted by the Philippine government to either

renegotiate with US representatives as ordered by this Court

or to strengthen our country’s position with regard to the

provisions of the VFA.

11.

Recent events, specifically, the grounding of USS Guardian inTubbataha Reef and our government’s reaction to it, have

once more underscored the difficult situation that continues to

face our government in properly enforcing the Visiting Forces

Agreement.

12. The US Navy website states that the incident occurred when

mine countermeasures ship USS Guardian (MCM 5) ran

aground on Tubbataha Reef at 2:25 a.m. local time, Jan. 17,

while transiting the Sulu Sea (Annex A).

1

13. US Navy information states that the Avenger-class mine

countermeasures ship had just completed a port call in Subic

Bay and was en route to Indonesia and then on to Timor-Leste

to participate in a training exercise when the grounding

occurred (Annex B).2

14. The circumstances surrounding the grounding of the ship

cannot be more telling regarding the attitude that the UnitedStates Navy has with regard to their Philippine counterparts

and their respect, or in this case, lack thereof, for Filipino

authorities even within the confines of Philippine waters.

15. News reports have stated that the crew of the ship was

warned that they were nearing the reef, but they did not take

heed and instead told the rangers to contact the US embassy

(Annex C). The Superintendent of the Tubbataha Management

Office, Angelique Songo has been quoted as saying:

"'Yung masama, hindi sila nagko-communicate.

Tinawagan nila (rangers) at sinabi nila sila ay patungo

1 http://www.navy.mil/submit/display.asp?story_id=71488

2 http://www.navy.mil/submit/display.asp?story_id=71553

http://www.navy.mil/submit/display.asp?story_id=71488








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roon. Ang sabi (ng taga) USS Guardian, kausapin ang

embahada, ang embahada ang kausapin sa bagay na

yan. (Kaya) hindi nila nakausap ang mga nasa bapor," 3

16. To further compound the situation, Ms. Songco also stated

that rangers were about to follow protocol of boarding a vessel

to check if it had the proper permit, but saw the

minesweeper's crewmembers were in "battle position" (Annex

D).4

17. The attitude shown by the crew of the USS Guardian is

reflective of what has long been experienced by many

Filipinos.

18. The blatant disregard for Philippine authority and the

disrespect shown to the rangers of the Tubbataha Reef

National Park by the crew of the USS Guardian show that the

VFA is unable to ensure that Philippine authority will be

respected by US forces.

19. This comes into sharper focus were this Court to consider that

in the VFA itself, specifically in its Art. II, the US declared that:

It is the duty of United States personnel to respect the

laws of the Republic of the Philippines and to abstain

from any activity inconsistent with the spirit of this

agreement, and, in particular, from any political activity

in the Philippines. The Government of the United States

shall take all measures within its authority to ensure that

this is done.

20. As with the case of the transfer of custody of Daniel Smith in

December 2006 from the Makati City Jail to the US Embassy

pending his imprisonment at the National Bilibid Prison at the

time when he was convicted of rape (Annex E),5 Petitioners

find that once more, Philippine sovereignty is not being given

its due respect by US forces.

21. Partly to blame are the unclear or inequitable provisions of the

VFA which do not address many issues and concerns that

3 http://ph.news.yahoo.com/uss-guardian-ignored-warnings-nearing-reef-tubbataha-management-

023035037.html 4 http://www.gmanetwork.com/news/story/291269/news/nation/uss-guardian-ignored-warnings-it-was-

nearing-reef-tubbataha-official 5 http://www.gmanetwork.com/news/story/148268/news/nation/sc-rules-against-daniel-smith-detention-at-

us-embassy

http://ph.news.yahoo.com/uss-guardian-ignored-warnings-nearing-reef-tubbataha-management-023035037.html




http://www.gmanetwork.com/news/story/291269/news/nation/uss-guardian-ignored-warnings-it-was-nearing-reef-tubbataha-official




http://www.gmanetwork.com/news/story/148268/news/nation/sc-rules-against-daniel-smith-detention-at-us-embassy










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Petitioners have encountered or will encounter in the future.

This includes the criminal liability of US Forces under Philippine

law.

22. For instance, Republic Act 10067 or the Tubbataha Reefs

National Park of 2009, apart from providing for the protection

of the reef and setting out how it is to be administered, is also

a penal statute. It contains multiple provisions penalizing such

as unauthorized entry into the Tubbataha Reefs National Park

among others.6

23. However, to date, apart from assurances of compensation and

working together to free the grounded ship (Annex F)

7

, nothinghas been said by the Philippine government or the US

government regarding the reason for the illegal entry of the

USS Guardian into the Tubbataha Reef National Park – for

whatever reason, possibly even for recreational purposes such

as diving - despite the clear warnings from local authorities.

24. In addition to this, apart from statements of apologies and

regret from the US government via the Commander of the US

Navy’s 7

th

Fleet (Annex G)

8

, there has been no mention from

6 Sec. 19. Unauthorized Entry, Enjoyment or Use. - No person or entity shall enter, enjoy or utilize any

portion of the TRNP and the resources therein for whatever purpose without prior permission from the

TPAMB as herein provided.

The TRNP shall be off-limits to navigation, except for activities that are sanctioned by the

TPAMB such as, but not limited to, tourism and research. Except in emergency situations, it shall be

unlawful to enter the TRNP without prior permission from the TPAMB or the PASu as herein provided. It

shall also be unlawful to enter, enjoy or use for any purpose any prohibited management zone. This rule

shall similarly apply to the use of vessels, gears and equipment in management zones where such are not

allowed.

Violation of this section shall be subject to imprisonment of not less than six (6) months but not

more than one (1) year imprisonment and a fine of One hundred thousand pesos (P100,000.00) but not

more than Three hundred thousand pesos (P300,000.00), as may be determined by the TPAMB. If the

violator is a commercial fisher/fisherfolk, the penalty shall be imprisonment of not less than one (1) year

but not more than three (3) years and a fine of Five hundred thousand pesos (P500,000.00).

Section 20. Damages to the Reef. - Damages to the reef shall subject the responsible person or entity to the

payment of administrative fines set by the TPAMB based on current valuation standards and to the

payment of the cost of restoration.

Section 30. Obstruction to Law Enforcement Officer. - The boat owner, master, operator, officer or any

person acting on his/her behalf, of any vessel who evades, obstructs or hinders any law enforcement officer

in the TRNP to perform his/her duty, shall be administratively fined Fifty thousand pesos (P50,000.00). In

addition, the registration, permit and/or license of the vessel including the license of the officers thereof

shall be cancelled.

Section 31. Common Penal Provision. -

(a)In case the vessel used in violation is owned by a corporation or entity, the fine shall be twice

the maximum amount imposed for the offense.(b)In case the vessel used in violation of this Act is foreign owned, the fine shall be thrice the

maximum amount imposed for the offense committed without prejudice to the provision of Section 27

hereof.

(c)The captain of the vessel shall suffer the maximum duration of the imprisonment for the offense

committed.7 http://www.gmanetwork.com/news/story/293562/news/nation/joint-phl-us-statement-on-the-uss-guardian-

grounding-on-tubbataha-reef 8 http://www.navy.mil/submit/display.asp?story_id=71563

http://www.gmanetwork.com/news/story/293562/news/nation/joint-phl-us-statement-on-the-uss-guardian-grounding-on-tubbataha-reef










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any US Military official of sanctions to the crew of the USS

Guardian as they also continue to remain mum the possible

criminal liability of the crew of the USS Guardian.

25. Even the Philippine government has not been forthcoming

about the criminal liability of the errant crew. Of late,

Secretary of Justice Leila de Lima has only commented that

they are waiting for results of investigations before considering

taking any action (Annex H)9.

26. What we know however is that the crew of the ship was

brought back to Sasebo, Japan, their homeport, without even

any contact or debriefing with local authorities. According to areport:

Navy officials would not speculate on the crew’s future

with the ship still stuck on Tubbataha Reef, a World

Heritage Site off the coast of the Philippines. But they

will remain together in Sasebo, their homeport, under

their commanding officer, Lt. Cmdr. Mark Rice, and will

train for “potential assignments” until further notice,

CTF-76 commander Rear Admiral Jeffrey Harley toldStars and Stripes (Annex I).10

27. It remains to be seen whether the crew of the USS Guardian

will ever be brought under Philippine jurisdiction again to face

charges for what was clearly a violation of not only domestic

but international laws as well given our prior experience in this

case.

28. The importance of the Tubbataha Reef to our country isemphasized by the fact that it is protected by domestic law

which is enforced against our own people. Yet here, we are

powerless to enforce our own legislation against the errant US

Navy crew.

29. The USS Guardian is still stuck on Tubbataha Reef. The US

Navy recently awarded a contract worth $25 Million for its

salvage to Singaporean firm SMIT. According to the contract,

the estimated time for the salvage will extend all the way toDecember 2013 (Annex J).11

9 http://www.gmanetwork.com/news/story/293534/news/nation/de-lima-we-ll-wait-for-tubbataha-probe-

results-before-taking-legal-action 10

http://www.stripes.com/news/sailors-back-home-in-sasebo-as-minesweeper-remains-stuck-on-reef-

1.205509 11

http://www.defense.gov/Contracts/Contract.aspx?ContractID=4972

http://www.gmanetwork.com/news/story/293534/news/nation/de-lima-we-ll-wait-for-tubbataha-probe-results-before-taking-legal-action




http://www.stripes.com/news/sailors-back-home-in-sasebo-as-minesweeper-remains-stuck-on-reef-1.205509












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30. Estimates have shown that the damage to the reef has reached

up to 4,000 square meters. With the number is likely to

increase as the process of salvaging begins since the salvageships will need to anchor causing even more reef damage

(Annex K).12

31. This is indeed a tragedy for our nation as the protected

Tubbataha Reef National Park continues to be damaged every

day.

32. The importance of the Tubbataha Reef cannot be more

emphasized. It is not only protected by domestic legislation, itis was declared as United Nations Educational, Scientific and

Cultural Organization (UNESCO) World Heritage Site in 1993

and was inscribed in the list of Ramsar list of Wetlands of

International Importance in 1999 (Annex L).13

33. According to UNESCO,

Tubbataha Reefs Natural Park contains excellent

examples of pristine reefs with a high diversity of marinelife. The property includes extensive reef flats and

perpendicular walls reaching over 100m depth, as well

as large areas of deep sea. The remote and undisturbed

character of the property and the continued presence of

large marine fauna such as tiger sharks, cetaceans and

turtles, and big schools of pelagic fishes such as

barracuda and trevallies add to the aesthetic qualities of

the property (Annex M).14

34. However, Tubbataha is not only valuable for its beauty. More

importantly, it has a high impact on the Philippines’ ecosystem.

UNESCO further describes it as:

Tubbataha Reefs Natural Park lies in a unique position in

the middle of the Sulu Sea and is one of the Philippines’

oldest ecosystems. It plays a key role in the process of

reproduction, dispersal and colonization by marine

organisms in the whole Sulu Sea system, and helpssupport fisheries outside its boundaries. Xx

12 http://www.philstar.com/headlines/2013/02/05/904988/dilemma-tubbataha-crane-needs-drop-anchor

13 http://tubbatahareef.org/wp/global_ecological_significance

14 http://whc.unesco.org/en/list/653

http://www.philstar.com/headlines/2013/02/05/904988/dilemma-tubbataha-crane-needs-drop-anchor



http://tubbatahareef.org/wp/global_ecological_significance



http://whc.unesco.org/en/list/653






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Xx Tubbataha Reefs Natural Park provides an important

habitat for internationally threatened and endangered

marine species.15

35. The Tubbataha Reef is literally the source of life for many

Filipino families who rely on fishing. Studies have shown that it

is a key source of coral and fish larvae which seeds the greater

Sulu Sea. It is important to Filipinos in the Palawan and Sulu

area as it plays a decisive role in sustaining the fisheries in

surrounding areas thus providing livelihoods to many Filipino

families.16

36.

With the grounding of the USS Guardian, once more we seethe potential destruction that US military presence has on our

country and our inability to do anything to counter it.

37. Clearly, as the Tubbataha Reef incident has shown, the entirety

of VFA is in dire need of review. Its provisions clearly do not

provide ample protection to Philippine interests.

38. In order to ensure that our sovereignty is not sacrificed and

our country is not shortchanged, we return to the instant case.

39. Here, the Supreme Court recognized the validity of the VFA,

albeit with multiple dissenting opinions not the least of which

came from then Chief Justice Renato Puno and Associate

Justice Antonio Caprio.

40. In their dissents, the eminent Justices clearly sets out the case

that there is an imbalance in the treatments of the Philippine

government and the US government of the VFA.

41. Justice Carpio, who was joined by Justice Alicia Austria-

Martinez and Justice Conchita Carpio Morales, reasoned that

his dissent was due to a supervening event that took place

between the Bayan v. Zamora (10 October 2000) case and the

events of this case.

42. He cited the United States Supreme Court decision in Medellin

v. Texas which ruled that a treaty, even if ratified by the UnitedStates Senate, is not enforceable as domestic federal law in the

United States unless Congress enacts the implementing

legislation or the treaty itself is self-executory.

15 Ibid.

16 http://tubbatahareef.org/wp/global_ecological_significance





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43. Justice Carpio emphasized wisdom of the framers in crafting

the requirement of Section 25, Article XVIII of the Philippine

Constitution that:

The other contracting state must “recognize as a

treaty” any agreement on the presence of foreign

troops in the Philippines, and such treaty must be

equally binding on the Philippines and on the other

contracting State.

44. What is worse, even in the solution proffered by the US

Supreme Court in Medellin for the wholesale ratification of thetreaties the US has entered into, the VFA is not one of the 70

treaties listed. This is because the US does not even consider

the VFA as treaty but as amere executive order.

45. As such, the dissent found that the VFA is incomplete and

ineffective and thus, unenforceable.

46. Similarly, in his very strong dissent, Chief Justice Puno stated:

I strongly dissented in the case of Bayan v. Zamora

proffering the view that the VFA falls short of the

requirement set by Section 25, Article XVIII of the 1987

Constitution stating that the agreement allowing

presence of foreign military troops in the Philippines

must be “recognized as a treaty by the other contracting

state.” The circumstances present in the case at bar and

recent case law in the United States’ policy on treaty

enforcement further expose the anomalous asymmetry in the legal treatment of the VFA by the United States

(U.S.) as opposed to the Republic of the Philippines (RP)

which I denounced in Bayan v. Zamora. This slur on our

sovereignty cannot continue, especially if we are the

ones perpetuating it . [emphasis ours]

47. Indeed, the pronouncements of the eminent Chief Justice have

been further emphasized by the incident in Tubbataha reef.

The treatment of the Philippines of US forces is in no wayequal to how the US forces treat the Philippines. By continuing

to abide by this patently unconstitutional agreement, we are

perpetuating this situation upon ourselves which is

unfortunate.

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48. The former Chief Justice further elucidated that:

The Philippine government has considered the VFA to

be fully enforceable within our jurisdiction; yet, theU.S. does not look at the VFA as enforceable within its

domestic jurisdiction. This dichotomy is evidently

proscribed by the Constitution, for such dichotomy

would render our sovereignty in tatters.

49. It is little wonder then that there is such blatant disregard by

US forces of Philippine authority even within our own territory.

While we consider hold binding authority of the VFA on our

territory in such high esteem, the US clearly does not.

50. Unfortunately, majority of the Court did not agree with the

well reasoned dissent of Chief Justice Puno.

51. It is also of note that the Tubbataha Reef incident is not the

first time that the VFA has caused unmitigated damage to

Philippine environment.

52. Just last year, Glenn Defense Marine Asia, a Malaysiancontractor used the VFA in trying to elude responsibility for

toxic chemical waste dumped in Philippine waters. This

prompted a call from some members of Congress, particularly

representatives from Partylist Group Gabriela, for the

termination of the VFA (Annex N).17

53. However, while the Majority of the Court found the VFA to be

constitutional, the Court also concluded that the Kenney-

Romulo Agreements relating to Section 10 or Article V of theVFA were not in accordance with the VFA.

54. Petitioners continue to maintain the unconstitutionality of the

VFA as a whole. However, it is worthwhile to take the

opportunity that the Court has given to properly enforce one

clarified provision of the VFA and in so doing prevent the

trampling of our sovereignty as what happened before with

the sudden whisking off of Daniel Smith from Philippine

custody in 2009.

55. Hence, we come back to the judgment that has been formerly

laid down by the Supreme Court in this case.

17 http://www.congress.gov.ph/press/details.php?pressid=6650

http://www.congress.gov.ph/press/details.php?pressid=6650




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56. Indeed, it is high time that the aforementioned decision be

actually followed as it would force our government to

renegotiate with the US government for the proper

enforcement procedure of a portion of the VFA which, asrecent history has shown, proven to be problematic.

57. Specifically, we ask that this Honorable Court enforce its ruling

for the renegotiation of the agreement between the United

States and Philippine government representatives as to proper

detention facilities for US military service people under

Philippine authorities, as it ruled in this case.

58.

While we believe that this Motion does not solve the biggerissue of the unfair and inequitable provisions and

unconstitutionality as a whole of the VFA, it is a step towards

ensuring that a portion of this defective agreement will not be

used again in the future to subvert Philippine interests.

59. Finally, it is important to note that the VFA does provide a

mechanism by which it can be terminated. Article IX of the

agreement states:

xx This agreement shall remain in force until the

expiration of 180 days from the date on which either

party gives the other party notice in writing that it

desires to terminate the agreement.

60. It is the Petitioners’ hope that the Philippine government sees

the need for renegotiating the entirety of the VFA and if

needed, to use the abovementioned section for abrogation in

case the Philippines cannot get a more equitable agreement.

61. It is recognized that the strategic alliance with the US are in

some ways beneficial. However, the negatives far outweigh

the benefits when the agreement, such as the current VFA, is

clearly unbalanced in its treatment of the two nations

involved.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that a

WRIT OF EXECUTION be issued by this Honorable Court on its Judgment

dated 11 February 2009 and that the Honorable Court order the Secretary

of Foreign Affairs to negotiate with the United States representatives for:

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(1) A more equitable and just Visiting Forces Agreement, and barring

that, abrogation of the Philippines from the agreement; or

alternatively(2) The appropriate agreement on detention facilities under

Philippine authorities as provided in Art. V, Sec. 10 of the Visiting

Forces Agreement as ordered by this Court.

Respectfully submitted .

Makati City for Manila, Philippines; 12 February 2013.

For the Petitioners

ROQUE & BUTUYAN LAW OFFICES

1904 Antel 2000 Corporate Centre

121 Valero Street, Salcedo Village

Makati City 1200

[email protected]

Tel. Nos. 887-4445/887-3894

Fax No: 887-3893

H. HARRY L. ROQUE

PTR No. 3692462/Jan 18, 2013/Makati City

IBP No. 499912/Lifetime/Makati City

Roll No. 36976

MCLE Exemption No. III-001000

(issued on 26 April 2010)

ROMEL REGALADO BAGARES

PTR No. 3692460/Jan 18,2013/Makati City

IBP No. 924439/Jan 10, 2013/SOCSARGEN

Roll No. 49518

MCLE Compliance No. IV-0011822

(issued on 25 January 2013)

ETHEL C. AVISADO PTR No. 1327231/Jan 8, 2013/Davao City

IBP No. 9033690/Sep 17, 2012/Davao City

Roll No. 56254

MCLE Compliance No. III-0022118

(issued on October 25, 2012)

mailto:[email protected]



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Copy Furnished:

ATTY. EVALYN G. URSUA

Rm. 305 AMAREMCA Building107-A Kalayaan Ave., Diliman

1101 Quezon City

LANCE CORPORAL DANIEL SMITH

c/o Department of Foreign Affairs

Roxas Boulevard, 2330 Pasay City

SECRETARY LEILA DELIMA

Department of Justice1000 Padre Faura, Manila

ATTY. PACIFICO AGABIN

Agabin Verzola Hermoso & Layaoen Law Offices

26th Floor, Pacific Star Building

Gil Puyat Ave., cor Makati Avenue

1200 Makati City

ATTY. ALBERTO SABATER CAGUIOAPresidential Legal Counsel

Mabini Hall, Malacañang Palace Compound

JP Laurel St., San Miguel

1005 Manila

ATTY. ANTONIO R. BAUTISTA

Bautista Law Building

30 Eugenio Lopez St., Diliman

1104 Quezon City

JUDGE BENJAMIN E. PUZON

Regional Trial Court, Branch139

1200 Makati City

SECRETARY MANUEL A. ROXAS II

Department of Interior and Local Government

A. Francisco Gold Condominium II

EDSA cor. Mapagmahal St., Diliman1104 Quezon City

HON. APOLINARIO D. BRUSELAS

Court of Appeals

Ma. Orosa Street, Ermita, 1000 Manila

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SECRETARY ALBERT DEL ROSARIO

Department of Foreign Affairs

Roxas Boulevard

2330 Pasay City

HON. BENIGNO SIMEON C. AQUINO III

President



1005 Manila

SOLICTOR GENERAL FRANCIS H. JARDELEZA

Office of the Solicitor General134 Amorsolo Street, Legaspi Village

1229 Makati City

EXECUTIVE SECRETARY PAQUITO OCHOA, JR.



1005 Manila

ATTY. JOSE P.P. JUSTINIANOSycip Salazar Hernandez and Gatmaitan Law Offices

SSHG Center, 105 Paseo de Roxas

Legaspi Village

1229, Makati City

H.E. HARRY K. THOMAS

Ambassador of the United States of America

To the Philippines

U.S. Embassy, Roxas Bouleverd1000 Manila

EXPLANATION

The foregoing pleading was sent by registered mail to the other parties in

accordance with the applicable Rules of Procedure due to time, distance

and personnel constraints.

Ethel C. Avisado

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