For over 50 years, the Philippines has In Bayan Muna v. Romulo, the Supreme recognized Court the agreements into by validity which the of had executive been executive may of government. An require be covered agreements executive agreement Senate does concurrence international law. treaty-authorized be concurrence matters executive or executive type of is a or a treaty-implementing in agreement, ratification) One agreement the form of treaties (require legislative after executive for Constitution, may by The Court cited the dynamic nature of the agreements the not executive international that is not cast in stone. efficacy. It is to be recalled, that under Philippine held categorization of subject matters that entered branch definitively executive which subject cover of the the same underlying treaty. agreements (similar to treaties, except that they do not require and are usudlly less formal and with a narrower matters). under legislative range law, difference between executive agreements effect negotiating remained of treated subject there treaties as in long within Philippine neither violates their domestic the as in executive which carries the same domestic law agreement. as An a valid identical approach is taken in the United States, no where and terms functionaries Under is Protocol, object and purpose of a treaty, may be deal The Court has reasoned that international binding A concurrence in US v. Belmont, the United of States Supreme Court declared that a the treaty not requiring ratification by the Senate—a have compact negotiated and proclaimed under the authority of the powers. President—was law, a “treaty” meaning of domestic law. Constitution. 24 within the