Several of the offenses are certainly capable of being described important. They deserve serious attention from law makers. However they are not “the most serious crimes” as international law defines that term. Because of the sovereign acts by which the Philippines accepts to be bound by international law, they cannot be made subject to the death penalty. Therefore, quite apart from the insurmountable issue of the Second Optional Protocol, each proposed law is inconsistent with the State obligations of the Philippines in international law, and the international legal responsibility of the Philippines for wrongful acts will be engaged if the proposed Bills become law. The Philippines is party to specific treaties which are inconsistent with the application of the death penalty to narcotics offences. Apart from international law instruments prohibiting the application of the death penalty to narcotics crimes, the Philippines is also a party to two treaties dealing specifically with these crimes. This study advances that proper interpretation of these treaties in a manner consistent with the VCLT makes it clear that the Philippines has agreed that narcotics crimes should not subject to the death penalty. The Philippines is a party to the 1961 Single Convention on Narcotic Drugs, which provides that Subject to its constitutional limitations, each Party shall adopt such measures as will ensure that cultivation, production, manufacture, extraction, preparation, possession, offering, offering for sale, distribution, purchase, sale, delivery on any terms whatsoever, brokerage, dispatch, dispatch in transit, transport, importation and exportation of drugs contrary to the provisions of this Convention, and any other action which in the opinion of such Party may be contrary to the provisions of this Convention, shall be punishable offences when committed intentionally, and that serious offences shall be liable to adequate punishment particularly by imprisonment or other penalties of 45 deprivation of liberty. The proper interpretation of the 1961 Convention is inconsistent with the imposition of the death penalty for narcotics offenses of any description. Clearly, the drafters of the 1961 Convention intended that the commission of a serious offense should be the subject to an appropriately grave sanction. However, the 1961 Convention makes reference only to the sanction of “imprisonment or deprivation of liberty”. A similar formulation (referring to imprisonment, deprivation of liberty, pecuniary 45 Single Convention on Narcotic Drugs, opened for signature Mar. 30, 1961, 520 U.N.T.S. 204 (entered into force Dec. 13, 1964), art. 36 (1). Page 15 of 23