- Ermita vs.

Magalona

- SC: There are limitations in using the straight baseline method. Art.
47 of UNCLOS:

1. A straight baseline should not exceed 100 nautical miles.

2. A straight baseline should not depart from the general configuration

or appearance of archipelago.

- Due to these limitations, Bajo de Masinloc (Scarborough Shoal) and

Kalayaan island Groups (Spratly’s Islands) in the general
configuration of the archipelago. Still, the Philippines has a claim in
these islands.

- If the islands are too far from the Philippines Archipelago, and will
violate the 100 nautical mile limit rule, the solution is to provide the
islands with Regime of Islands.