denunciation or withdrawal; or a right of denunciation or withdrawal may be implied by the nature of the treaty. 2. A party shall give not less than twelve months' notice of its intention to 24 denounce or withdraw from a treaty under paragraph 1. The Second Optional Protocol does not carry the necessary implication of such a right of withdrawal. In fact, to the contrary, every aspect of the Second Optional Protocol, its object and purpose, and the travaux préparatoires make it clear that no withdrawal from the Protocol, once ratified, is permissible. Even if that conclusion was (hypothetically) wrong, a minimum period of notice of twelve months is required to effect a withdrawal from the Second Optional Protocol, following Article 56 of the VCLT. It would be expected that all other States party to the Second Optional Protocol would protest such a course in the most vigorous terms. International law restricts the application of the death penalty to the “most serious crimes.” Even if the Philippines was not a party to the Second Optional Protocol, it is in any event bound by clear and unambiguous international laws which severely restrict the threat or use of the death penalty. International law, both treaty and customary, plainly prevents the imposition of the death penalty for anything other than the most serious crimes. All of the proposed Bills are inconsistent with that rule of international law, because they propose the reintroduction of the death penalty for crimes that do not fall within the definition as “the most serious” crimes. The Philippines is a party to the ICCPR, which was drafted in the recognition that, at the time of its conclusion, the death penalty is not illegal per se but that its application should be severely limited. Article 6 of the ICCPR relevantly provides as follows: (1) Every human being has the inherent right to life. This right shall be protected by law. No one shall be arbitrarily deprived of his life. (2) In countries which have not abolished the death penalty, sentence of death may be imposed only for the most serious crimes in accordance with the law in force at the time of the commission of the crime and not contrary to the provisions of the present Covenant and to the Convention on the Prevention and Punishment of the Crime of Genocide. This penalty can only be carried out pursuant to a final judgement rendered 25 by a competent court. (Emphasis supplied.) 24 VCLT, art. 56. International Covenant on Civil and Political Rights, opened for signature Dec. 16, 1966, 999 U.N.T.S. 171 (entered into force Mar. 23, 1976) [hereinafter ICCPR], art. 6. 25 Page 10 of 23