South China Sea Dispute

Submitted by:

Maria Casimir Acuin

Domingo Francisco
Arven Mendoza
Celso Morada Jr.
Josine Orejola
Mark Vincent Padua
Roberto Jose Ronquillo
Reginald Villarosa
Table of Contents

Background 3
Vietnam Claim 3
Brunei Claim 4
Malaysia Claim 4
Taiwan Claim 5
Philippines Claim 5
China Claim 6

Statement of the Problem 7

Review of Related Literature 7

Historical Claim 7
Legal Framework 13
Bilateral Negotiations 13
Similar Case 13

Discussion 14
A. Philippines and its Decision to Conform to UNCLOS 14
B. 9 Dash line and the International Community Acceptance 15
C. China as one of the parties that agreed to UNCLOS 1982 15
D. Ramifications of strictly following UNCLOS 1982 16

Recommendation 16

References 17
 I. Background

The South China Sea (SCS) is regarded as one of the most significant bodies of water in

the world. SCS has been a desirable territory for surrounding states as it contains a vast amount of

natural resources. Moreover, SCS is a strategic critical area for international trade. In fact,

according to the U.S Energy Information Administration, 190 trillion cubic feet of natural gas and

11 billion barrels of oil reserves were to be stored in the area.

SCS has also been ranked as the second most active sea lane in the world. There exist 5.3

trillion dollars worth of sea trade in the SCS, which takes up a third of the global trade.

In the past years, territorial claims over the South China Sea brought about disputes among

the claimants. As of date, the claimants are the Philippines, Vietnam, China, Brunei, Taiwan, and

Malaysia. These states claim different territorial/ maritime rights over SCS based on various

accounts of history and geography.

Vietnam Claim

Vietnam claims that the entire Spratly Islands is an offshore district of the province of

Khanh Hoa based on history and the continental shelf principle. Their claims, although not clearly

defined, also cover an extensive area of the South China Sea. Vietnam used archaeological

evidence to bolster sovereignty claims over SCS. This led France to claim Spratly and Paracel

Islands on behalf of its then-colony Vietnam in the 1930’s. At present, Vietnam controls 21 islands,

reefs, shoals, and cays of the Spratly Islands.

Vietnam likewise claim rights over the Paracel Islands. However, China took ownership

over the islands in 1974.

 Recently, a group of Vietnamese experts suggested that Vietnam should take legal action

against China for violating Vietnam’s sovereignty under international law at The Hague.

Brunei Claim

Brunei claims a 200-nautical mile EEZ under the terms of UNCLOS, in addition to several

land features within its legal boundaries in the southern portion of the sea. This includes Louisa

Reef, Owen Shoal, and Rifleman Bank. Contrary to the other claimants, Brunei does not occupy

any land within the SCS. Correspondingly, Brunei does not enforce its claim on the SCS and

maintains no permanent military presence in the area.

When Brunei gained its independence in 1984, a map was released. The map was updated

in 1988 from which the boundaries of Brunei’s proposed EEZ is reflected upon. Despite the

indication of its claim in the updated map, the country continues to remain silent about the issue.

This leaves Brunei’s claim in uncertainty.

Brunei has been experiencing an economic downturn due to the decline of oil and gas

reserves. In view thereof, it can be construed that Brunei has remained silent about its territorial

claim on the SCS as Brunei now heavily relies on China for its economic growth.

Malaysia Claim

The claims of Malaysia are based upon the continental shelf principle, and have clearly

defined coordinates. Malaysia occupies three islands considered to be within its continental shelf:

Ardasier Reef (Terumbu Ubi), Mariveles Reef (Terumbu Mantanani) and Swallow Reef (Terumbu

Layang).

In a recent article, Malaysian Foreign Minister Datuk Saifuddin Abdullah mentioned that

they are seeking to discuss the South China Sea issue in an Asean-centric way. This means all the
claimants would have to be involved in the talks. Malaysia dissents from the bilateral based

method of discussion about the issue favoured by China.

Taiwan Claim

Taiwan's claims are similar to those of China and are based upon the same principles. In

like manner , Taiwan's claims are not clearly defined. However, Taiwan controls Itu Aba [Taiping

Dao] Island, the largest single island among the Spratlys.

Taiwan discontinued its claims following the 2005 suspension of the ROC’s 1993 Policy

Guidelines for the South China Sea, according to Chi-Ting Tsai, an assistant professor of

international law at National Taiwan University. Nonetheless, the guidelines were merely

suspended, which leaves the possibility that Taipei’s U-shaped line could again be revived

according to Tsai.

Philippines Claim

The Philippines' claims on the Spratlys have clearly defined coordinates and based both

upon the proximity principle as well as on the explorations of a Philippine explorer in 1956. In

1971, the Philippines officially claimed eight islands that it refers to as the Kalayaan, partly on the

basis of this exploration, arguing that the islands: 1) were not part of the Spratly Islands; and 2)

had not belonged to anybody and were open to being claimed. In 1972, they were designated as

part of Palawan Province, Kalayaan municipality. The total land area of these islands is 790,000

square meters.
 The Philippines control the following islands in the Spratlys: Kota or Loaita Island, Lawak

or Nansham Island, Likas or West York Island, Panata or Lamkian Cay, Pag-asa or Thitu Island,

Parola or North East Cay, Patag or Flat Island, Rizal or Commodore Reef

In 2013, the Philippines filed an arbitration case against China at the United Nations-backed

Permanent Court of Arbitration (PCA) to settle the maritime dispute and invited China to join the

proceedings. China officially rejects the move to bring the long-running territorial issues over the

South China Sea before the PCA, saying Manila's claim is "legally infirm and carried unacceptable

allegations against Beijing". In 2016, the tribunal ruled that China has "no historical rights" based

on the "nine-dash line" map. China has rejected the ruling, as has Taiwan.

China Claim

China refers to the Spratly Islands as the Nansha islands, and claims all of the islands and

most of the South China Sea for historical reasons. These claims are not marked by coordinates

and therefore not clearly defined.

Chinese claims are based on a number of historical events, including the naval expeditions

to the Spratly Islands by the Han Dynasty in 110 AD and the Ming Dynasty from 1403-1433 AD.

Chinese fishermen and merchants have worked the region over time, and China is using

archaeological evidence to bolster its claims of sovereignty.

In the 19th and early 20th century, China asserted claims to the Spratly and Paracel islands.

During World War II, the islands were claimed by the Japanese. In 1947, China produced a map

with 9 undefined dotted lines, and claimed all of the islands within those lines. A 1992 Chinese

law restated its claims in the region.

 China has occupied some of those islands. In 1976, China enforced its claim upon the

Paracel Islands by seizing them from Vietnam. China refers to the Paracel Islands as the Xisha

Islands, and includes them as part of its Hainan Island province.

Currently, China has control over these islands: Cuarteron Reef, Fiery Cross Reef, Gaven

Reef, Hughes Reef, Johnson Reef, Mischief Reef, Subi Reef

II. Statement of the Problem

What resolution of the South China Sea can please both the Philippines and China?

III. Review of Related Literature

A. Historical Claim

China’s 9 Dashed Line

The eleven-dash line of the Republic of China was first internally circulated in 1947 as an

atlas that indicated the geographical scope of its authority over the SCS (Sakamoto, 2015). In 1953,

when the territorial title for Bach Long Vi island was transferred to China from Vietnam, China

decided to remove two dashes making it the nine-dash line (9DL).

The 9DL entitles China to 90% of Brunei’s Exclusive Economic Zone (EEZ), 80% of

Malaysia’s EEZ, 80% of the Philippines’ EEZ, 50% of Vietnam’s EEZ, and 30% of Indonesia’s

EEZ(Carpio, 2017). China claims “sovereignty” over 70% of the Sea’s waters and underlying

seabed within the 9DL.

China has four legal interpretations of the 9DL:

● The line delineates the ‘scope of historical rights’. This includes the rights to develop

resources and fish as previously exercised by China;

 ● The line serves as the ‘line of attribution of the islands therein’. China’s intention or will

taking into consideration the occupation of the islands therein;

● The line as the ‘limits of historic waters’ which serves as the indication of the bounds of

China’s historical and traditional sovereignty;

● The line as the ‘traditional border line' or the traditional sphere of China’s influence.

B. Legal Framework

Law of the sea emerged from the struggle of coastal states that seek to expand their

maritime claims adjacent to coastlines. The international community, after WWII, requested UN

international commission to codify existing laws of the oceans. There are three UN Conventions

on the Law of the Sea (UNCLOS):

● UNCLOS I, from February 24 to April 29, 1958, commonly known as 1958 Geneva

Conventions was considered a step forward but did not establish the scope of territorial

sea.

● UNCLOS II, from March 17 to April 26, 1960, did not result in any internal agreements

and still failed in stipulating breadth for territorial or sovereign fishing rights.

● UNCLOS III, from 1973 to 1982, participated by 160 countries addressed the issues

brought up by previous conventions. UNCLOS III defined maritime zones, continental

shelf, high sea, international see-bed area, archipelagic waters, navigation provisions,

maritime environment protection, scientific research freedom, resources exploitation, and

disputes settlement.

(GRID-Arendal. 2004)

Carpio (2017) in his book The South China Sea Dispute: Philippine Sovereign Rights and

Jurisdiction in the West Philippine Sea illustrated the maritime zones under UNCLOS.
 In 2009, Vietnam and Malaysia submitted their extended continental shelf claims to United

Nations (UN); however, China protested the claims and submitted its nine-dashed line map as

counter-argument. China asserted their “indisputable sovereignty” over the islands in the South

China Sea and the adjacent waters and “sovereign rights and jurisdiction” over the relevant waters,

seabed and subsoil.

China’s nine-dashed line claim does not comply with UNCLOS requirements for maritime

entitlements must be measured from coast of continental land, island or rock above water at high

tide (Articles 3, 57 & 76, UNCLOS) as guided by the doctrine in the Law of the Sea - “land

dominates the sea”. This was also echoed by judge Zhiguo Gao (2013), a Chinese legal scholar,

and Prof. Bing Bing Jia and Keyuan Zuo (2012).

In 2013, China added a tenth dash claiming the eastern side of Taiwan and claimed that the

ten dashes covers their “national boundary”. In June 2013, the Philippines expressed objection that

the dash line represents China’s boundary in the South China Sea for a state’s “national boundary”

is its national territory.

 China’s “national boundary” affects the Philippines’ entitlement of 80% of Exclusive

Economic Zone (EEZ) and 100% of Extended Continental Shelf (ECS). The Philippines’ national

interest is to protect its EEZ. The protection of national interest is the Philippine’s primary

motivation in filing an arbitration case against China through UNCLOS tribunal where the issue

could be resolved peacefully according to the Law of the Sea. (Carpio, 2017)

The Philippines Arbitration case against China only involves maritime disputes aligned

with UNCLOS. On July 12, 2016, the Permanent Court of Arbitration rules in favor of the

Philippines. The court ruled that:

● China’s claim of historic rights as described by 9-dash line has no legal basis

● Reclaimed islands is not an extension of maritime zones.

● “China had violated the Philippines; sovereign rights in its EEZ”

● China’s reclamation in the disputed area “caused severe harm to the coral reef

environment and violated its obligation to preserve and protect fragile ecosystems”

● Island building should have stopped during the arbitration process.

(Perlez, 2016; Esmaquel, 2016)

C. Bilateral Negotiations

Months after the arbitration case ruling, President Rodrigo Duterte marked a reversal in the

country’s foreign policy by announcing his separation from the US and declaring his realignment

with China during his first state visit to China in October 2016 (Blanchard, 2016). During this

visit, the Philippines and China have agreed to resolve the dispute on the South China Sea through

bilateral talks. According to the Joint Statement of the Republic of the Philippines and the People’s

Republic of China issued in October 2016:

 “Both sides agree to continue discussions on confidence-building measures
to increase mutual trust and confidence and to exercise self-restraint in the
conduct of activities in the South China Sea that would complicate or
escalate disputes and affect peace and stability. In this regard, in addition to
and without prejudice to other mechanisms, a bilateral consultation
mechanism can be useful, which will meet regularly on current and other
issues of concern to either side on the South China Sea. Both sides also
agree to explore other areas of cooperation.”

On May 19, 2017, the First Meeting of the Philippines-China Bilateral Consultation

Mechanism on the South China Sea (BCM) was held in Guiyang, Guizhou Province, China. The

Terms of Reference (TOR) was initialed by the Heads of Delegation during the said meeting. They

agreed that the TOR “should be a platform for confidence-building measures and for promoting

maritime cooperation and maritime security.” Equivalent officials from the respective foreign

ministries and relevant maritime affairs agencies will be included in the BCM and will meet once

every six months alternately in the Philippines and China.

On the second meeting of the BCM on the South China Sea held on February 13, 2018 in

Manila, issues related to developments in the South China Sea and possible cooperative activities

were discussed in order to build mutual trust and confidence and to further enhance bilateral

relations between the two countries.

The Philippines and China reaffirmed their commitment to the principles of freedom of

navigation in the South China Sea, freedom of international commerce, and other peaceful uses of

the sea during the third BCM on the South China Sea, which was held on October 18, 2018 in

Beijing, China. In the course of the talks, they also agreed to address the disputes on territories

through “friendly consultations and negotiations” among the involved sovereign states.

During the state visit of Chinese President Xi Jinping in November 2018, the Philippines

and China signed a total of 29 Memoranda of Understanding (MOU) including deals in the fields
of trade and investment, banking and finance, infrastructure, agriculture, education, culture and

people-to-people exchanges. Topping the list of the documents signed was the MOU on

cooperation on oil and gas development, which stated that the two governments have decided to

negotiate on an accelerated basis arrangements to facilitate oil and gas exploration and exploitation

in relevant maritime areas consistent with applicable rules of international law.

The fourth BCM on South China Sea was convened in April 2019 in Manila. During this

meeting, “both sides reiterated that while the contentious issues in the South China Sea should not

be ignored, they are not the sum total of the Philippines-China relations and should not exclude

mutually beneficial cooperation in other fields”. Both sides also reaffirmed the importance of

maintaining and promoting regional peace and stability, freedom of navigation in and over-flight

above the South China Sea. Both sides reiterated their commitment to address disputes by peaceful

means, without resorting to the threat or use of force, through friendly consultations and

negotiations by sovereign states directly concerned, in accordance with universally recognized

principles of international law, including the Charter of the United Nations and the 1982 United

Nations Convention on the Law of the Sea (UNCLOS).” Both countries have also “reiterated their

commitments to full and effective implementation of the 2002 Declaration on the Conduct of

Parties in the South China Sea and agreed to maintain the positive momentum of the negotiations

towards the early conclusion of a Code of Conduct in the South China Sea, based on consensus.”

During President Duterte’s fifth visit to China in August 2019, the Philippines and China

have agreed on the creation of a steering committee that would finalize the possible agreements

on the joint oil and gas exploration, and also on the terms of reference of the said joint exploration.

Moreover, the two countries have also signed MOU’s related to economic growth, education, and

science and technology during this bilateral meeting. President Duterte has also brought up the
2016 arbitration case ruling in favor of the Philippines, which Chinese President Xi Jinping still

refused to recognize.

D. Similar Case

Bangladesh v. Myanmar: Delimitation of the Maritime Boundary between Bangladesh and

Myanmar in the Bay of Bengal

The judgement of the International Tribunal for the Law of the Sea (ITLOS) in the maritime

dispute between Bangladesh and Myanmar has two international law contributions:

1. Delimitation of the continental shelf beyond 200-nautical-mile limit (Outer Continental

Shelf)

2. First maritime boundary delimitation decided by ITLOS

The landmark decision provided guidance in cases that involve OCS and in discussion of

delimiting maritime boundaries (Magnusson, 2012). For territorial, the Tribunal used the

equidistance principle from the baseline identified in accordance with UNCLOS. For EEZ and

continental shelf within 200 nm, the Tribunal was asked to draw the maritime boundary that would

achieve equitable results. In addition, the Tribunal decided that “the delimitation method...for

continental shelf beyond 200 nm should not differ from that within 200nm”. Although the case

sets precedence in adjudicating maritime boundary claim, it failed to address the proper

characteristics and definitions of “islands” and corresponding EEZ and continental shelf

requirements (Balaram, 2012).

IV. Discussion

A. Philippines and its Decision to Conform to UNCLOS

“West Philippine Sea is ours and ours alone!”

- Pres. Duterte, SONA 2019

With the decision granted in favor of the Philippines, China has no claim to step on our

maritime right of territorial integrity, as provided for in our constitution (Sec 1, Art 1, 1987 Phil

Constitution). These were the provisions conceded to us by the international tribunal, backed by

the jurisdictions of UNCLOS. The decision to conform to the maritime laws provided by the

United Nations convention is strongly based on the Philippine constitution which renounces war

as an instrument for national policy, as well as to adopt to the generally accepted principles of

international law (Sec 2, Art 2, 1987 Phil Constitution). The Philippines aligned its baseline to

conform with UNCLOS with Republic Act No. 9522 which was enacted in 2009(Carpio, 2017).

Peace, as the main criteria of negotiation, is what the Philippines hopes to achieve, as stipulated in

the first paragraph of the preamble to UNCLOS; “desire to settle, in a spirit of mutual

understanding and cooperation”, with these stipulations embodied in the agreement made by each

nation, China and all other countries have nothing more than to respect the tribunal and its ruling.

The Philippines has already recognized its right over the disputed area, none-the-less it wanted to

solidify its claims by respecting the law and conforming to the authority that governs it. With the

intervention of the United Nations, it seeked to peacefully resolve the conflict and award the rights

over the disputed area to be granted to the rightful holder. Though China has its claims based on

their “historical rights”, Justice Antonio Carpio deemed this as “futile as it holds no bearing under

UNCLOS” as historical rights have been extinguished by the UNCLOS, instead providing nations

with the Exclusive Economic Zone (EEZ).

 B. 9 Dash line and the International Community Acceptance

The legal nature and meaning of the 9DL itself is considered controversial and ambiguous

under the UNCLOS (Sakamoto, 2015). Dupoy.F and Dupoy.P-M(2013) clearly state that “Maps

do not constitute titles in international law”. They use the frontier dispute between Burkina Faso

and the Republic of Mali as a clear example of this statement.

The courts take the following factors into consideration when a state files for a historic title

(Korkut & Kang, 20117):

1. The parties involved had a common perception of the Island’s Existence. It must

be proven that there is a common perception that the maritime territory belongs to a party since

time immemorial.

2. The territorial regime of the region and time. Parties involved must at least share a

common perception that a state has been used by other States. In the case of Eritrea v. Yemen, the

court dismissed the Yemeni claims of their “ancient title” because medieval Yemen did not have

a concept of territorial sovereignty.

3. Existence of rival claims. Awarding of the territory is simplified if there are no

other claims for the said territory.

C. China as one of the parties that agreed to UNCLOS 1982

The United Nation Convention on the Law of the Sea (UNCLOS) is an international treaty

which was adopted and signed in 1982, that defines the limits of the territorial seas of nations and

the areas in which they could exploit marine resources. It also established the rules for the use of

the high seas for international navigation and outline the rights and responsibilities of nation in the

protection of the marine environment. As to date, there are 168 parties joined and agreed in the
convention (167 states, and the European Union). One of the signatories is the People’s Republic

of China. On July 12, 2016, the arbitral tribunal ruled and dismissed China's territorial claims in

the South China Sea, saying it has “no historic title” to the vast maritime region. However, China

refused to recognize the Permanent Court of Arbitration’s ruling nor does Beijing even accept the

U.N. tribunal’s authority over its South China Sea Claims making the decision more than just a

piece of waste paper.

D. Ramifications of strictly following UNCLOS 1982

Considered as the "constitution for the oceans,'' UNCLOS aims to define the maritime

areas, as well as the rights and duties of countries in terms of navigation, exploitation of resources,

and protection of the marine environment. However, the U.N. Convention for the law of the sea

has no enforcement power unless the country affected comply with the decision of arbitral

tribunals.

Recommendation

The UNCLOS, being regarded as the highest law with regard to disputes of sea territory,

should be considered with great respect and the Philippines, China, and all other signatories of the

United Nations Convention has no right to disregard any resolution provided. All historical rights,

including that of China, has already been superseded by the regimes of exclusive economic zone

and continental shelf established under the Convention (Ma, 2018). These were just some of the

facts afforded by the high tribunal in favor of the Philippines, and these were all backed by the

stipulations specified by law when it stated that all historical claims are to be arbitrated by

International Law. We, as a group, favorably agree with the high tribunal and it’s decision to

declare the disputed islands as part of the Philippine territory. Despite the words granted by the
judges of the UNCLOS; “China shall desist from further unlawful claims and activities” (PCA

Case No. 2013-19), tensions still continue to rise with China persisting on pursuing the disputed

area. There may be no impending resolution with regard to this tension, however with the backing

of the United Nations Convention and a growing support for the entitlements of the Philippines,

we strongly believe that we may still claim what is ours through a peaceful negotiation.

The group would recommend that the Philippines and China pursue bilateral negotiations

since since the decision of the arbitral tribunal is not fully respected and there is no enforcement

power. While pursuing negotiations, the Philippines should use the arbitration ruling to gain

leverage over China since it already has support from the international community. We would like

to quote Mr Panelo through an article released on April 30, 2019 “..You don’t resolve the conflict

by going to war or armed hostilities; it will not solve anything. In fact, all the conflicts in the world

when not resolved by means of negotiations end up in armed hostilities.”

To enhance bilateral relations between both countries, the negotiations must be built on a

strong foundation. The TOR must be a platform for encouraging maritime security and

cooperation. The relationship shall be built on mutual trust and confidence.

In the meantime, both countries have already signed a total of 29 MOUs that include deals

in the fields of banking and finance, infrastructure, education, culture, trade and investment and

people exchanges. The most critical MOU was the joint oil and gas exploration.

References

Balaram, Ravi A. (2012), Case Study: The Myanmar and Bangladesh Maritime Boundary Dispute
in the Bay of Bengal and Its Implications for South China Sea Claims, in: Journal of Current
Southeast Asian Affairs, 31, 3, 85-104. ISSN: 1868-4882 (online), ISSN: 1868-1034

Carpio, Antonio. 2017. The South China Sea Dispute: Philippine Sovereign Rights and
Jurisdiction in the West Philippine Sea
 Choong, J. (2019, May 13). Malaysia wants to resolve South China Sea dispute together
as Asean, minister says. Retrieved from
https://www.malaymail.com/news/malaysia/2019/05/13/malaysia-wants-to-resolve-
south-china-sea-dispute-together-as-asean-ministe/1752299

Dupoy, F. & Dupur P. (January 2013). A Legal Analysis of China's Historic Rights Claim in the
South China Sea. The American Journal of International Law, Vol. 107, No. 1 pp. 124-
141

GlobalSecurity.org. (2011, November 7). Territorial claims in the Spratly and Paracel
Islands. Retrieved from https://www.globalsecurity.org/military/world/war/spratly-
claims.htm

GRID-ARENDAL. (2004). Continental Shelf Programme. Retrieved from .

http://www.continentalshelf.org/

Hart, M. (2018, April 4). Brunei Abandons South China Sea Claim for Chinese Finance.
Retrieved from https://www.geopoliticalmonitor.com/brunei-abandons-south-china-sea-
claim-for-chinese-finance/

Heydarian, R. (2019, October 10). Vietnam a lonely island of resistance to China.

Retrieved from https://www.asiatimes.com/2019/10/article/vietnam-a-lonely-island-of-
resistance-to-china/

Kang, W. & Korkut E. (June, 2017) China's Nine Dash Line Claim in Light of the
Ruling by the Permanent Court of Arbitration (12July 2016). Penn State Journal of Law &
International Affairs. Vol. 5, Issue 2 Contemporary Writings in a Global Society: Collected
Works, pp 426-463.

Magnusson, Bjarni Mar. 2012. Judgment in the dispute concerning delimitation of the maritime
boundary between Bangladesh and Myanmar in the Bay of Bengal. Aspen Publishers, Inc.

Paterno, Esmaquel II. July 13 2016. Philippines wins case vs China. Retrieved from :
https://www.rappler.com/nation/137202-philippines-china-ruling-case-west-philippine-
sea

Perlez, Jane (12 July 2016). "Tribunal Rejects Beijing's Claims in South China Sea". The New
York Times. ISSN 0362-4331
 Sanchez, R. (2016, July 12). TIMELINE: The Philippines-China maritime dispute.
Retrieved from https://www.rappler.com/world/regions/asia-pacific/139392-timeline-
west-philippine-sea-dispute

Sands, G. (2019, June 28). Rethinking Taiwan’s Claims in the South China Sea. Retrieved
from https://thediplomat.com/2019/06/rethinking-taiwans-claims-in-the-south-china-sea/

United States Energy Information Administration retrieved from:

https://www.eia.gov/beta/international/analysis_includes/regions_of_interest/South_Chin
a_Sea/south_china_sea.pdf

Zhiguo Gao & Bing Bing Jia, The Nine-Dash Line in the South China Sea: History, Status and
Implications, 107 Am. J. Int’l L. 98, 108-10 (2013);

Zou Keyuan. 2012. China’s U-Shaped Line in the South China Sea Revisited, 43 Ocean Dev. &
Int’l L. 18 .

Blanchard, B. (2016, October 20). Duterte aligns Philippines with China, says U.S. has lost.
Reuters. Retrieved from https://www.reuters.com/article/us-china-philippines/duterte-
aligns-philippines-with-china-says-u-s-has-lost-idUSKCN12K0AS

Department of Foreign Affairs. (2016). Joint statement of the Republic of the Philippines and the
People's Republic of China. Retrieved from https://www.dfa.gov.ph/dfa-releases/10748-
joint-statement-of-the-republic-of-the-philippines-and-the-people-s-republic-of-china

Department of Foreign Affairs. (n.d.). Joint press release for the first meeting of the
Philippines-China bilateral consultation mechanism on the South China Sea. Retrieved
from https://www.dfa.gov.ph/dfa-releases/12694-joint-press-release-for-the-first-
meeting-of-the-philippines-china-bilateral-consultation-mechanism-on-the-south-china-
sea

Department of Foreign Affairs. (2018, February 14). PH-CH convenes second meeting of the
bilateral consultation mechanism on the South China Sea (SCS). Retrieved from
https://dfa.gov.ph/dfa-news/dfa-releasesupdate/15564-ph-ch-convenes-second-meeting-
of-the-bilateral-consultation-mechanism-on-the-south-china-sea-scs

Department of Foreign Affairs. (2018, October 18). Third Meeting of the Philippines-China
bilateral consultation mechanism. Retrieved from https://dfa.gov.ph/dfa-news/dfa-
releasesupdate/18199-third-meeting-of-the-philippines-china-bilateral-consultation-
mechanism-bcm
Department of Foreign Affairs. (2019, April 3). Philippines, China Convene the Fourth Meeting
of the Bilateral Consultation Mechanism on the South China Sea. Retrieved from
https://dfa.gov.ph/dfa-news/dfa-releasesupdate/18199-third-meeting-of-the-philippines-
china-bilateral-consultation-mechanism-bcm

CNN Philippines. (2019, August 30). PH, China sign six agreements during Duterte's 5th visit.
Retrieved from https://www.cnnphilippines.com/news/2019/8/30/Philippines-Duterte-
China-Xi-bilateral-agreements.html

Esguerra, D. (2018, November 26). Palace releases PH-China MOU on oil and gas development.
The Philippine Daily Inquirer. Retrieved from
https://newsinfo.inquirer.net/1057145/palace-releases-ph-china-mou-on-oil-and-gas-
development

Ramos, C. (2019, October 11). Cusi: meeting being set for PH, Chinese execs on joint oil, gas
exploration. The Philippine Daily Inquirer. Retrieved from
https://globalnation.inquirer.net/180955/cusi-meeting-being-set-for-ph-chinese-execs-on-
joint-oil-gas-exploration

MA, X. (2018). Merits Award Relating to Historic Rights in the South China Sea Arbitration: An
Appraisal. Asian Journal of International Law, 8(1), 12-23.
doi:10.1017/S2044251317000236