Philippines in 2007, twenty years after the passage of the Constitution, is a valid sovereign act of the Philippines as a matter of international law. The Philippines may not withdraw from the Second Optional Protocol as this treaty unambiguously prohibits, permanently, the imposition of the death penalty in the Philippines for all crimes. The VCLT, to which the Philippines is a party, requires the state to comply with its treaty obligations and perform them in good faith. That is also an obligation binding upon the Philippines as a matter of customary international law. International law does not permit withdrawal from, nor denunciation of, the Second Optional Protocol. Once ratified by a State, its obligations are binding and perpetual. Even if that conclusion was (hypothetically) wrong, a minimum period of notice of twelve months would be required to effect a withdrawal from the Second Optional Protocol. It would be expected that all other States party to the Second Optional Protocol would protest such a course in the most vigorous terms. The Bills that are before the House of Representatives and the Senate are in any event inconsistent with the international legal obligations of the Philippines because they seek to re-impose the death penalty for crimes that are not “the most serious crimes.” The Philippine Constitution itself prohibits the imposition of the death penalty for crimes that are not “heinous.” “Heinous” has the same meaning as “the most serious” both because of the decisions of the Supreme Court of the Philippines and because international law is part of the law of the land of the Philippines by Article II, Section 2 of the Constitution. Passage of any of the Bills will trigger the international responsibility of the Philippines and it will commit an internationally wrongful act. Page 23 of 23