yearas baseline, criminality increased by 15.3% or a total of 82, 538 (from 71, 527 crimesin the previous year).?5 it. According to Florence Bellivier, FIDH?° Deputy-Secretary General, "the pretext of using the death penalty to fight wars on drugs and terrorism are merely a quick fix for governments who are eager to showthey are tough on crime. The reality is that the death penalty has no deterrent effect on the commissionof crimes, particularly those that are drug-related or alleged acts of terrorism.?”” i: Supporters of the re-imposition of the death penalty avers that the Constitution allows the imposition of death penalty where there are compelling reasons involving heinouscrime.?8 But this begs the question: Are there compelling reasons to warrantthelegislative restoration of the death penalty? Do the fluctuation of the crime rate and the atrocity of the crime considered as compelling reasonsto justify the reimposition of death penalty? 13. The Philippines is boundto honor its international commitments under the Jaw of nations. The Philippines by acceding to treaties has bound itself to observe it in good faith based on the international principle of pacta sunt servanda. Considered as one of the oldest and most fundamental rules in international law, the rule was madeexplicit in the Vienna Convention on the Lawof Treaties, which provides that every treaty in force is binding upon the parties to it and must be performed by them in goodfaith. 14. The goodfaith element of this principle suggests that states should take the necessarysteps to comply with the object and purposeofthe treaty. As a rule, states maynot invokerestrictions imposed by domestic law as good reason for not complying with their treaty obligations provided the instrument was duly ratified by competent authorities and in accordance with constitutional and statutory requirements.#° 15. TheInternational Covenanton Civil and Political Rights (ICCPR) prescribed a progressive obligation amongnations to abolish death penalty and prevent its reimposition. Article 6 (6) is explicit whenit states that nothing in this article shall be invoked to delay or to prevent the abolition of capital punishmentbyanyState Party to the present covenant. 16. The Second Optional Protocol to the ICCPRclearly calls upon State Parties to take all necessary measures to abolish the death penalty and states that no one within the jurisdiction of a State Party to the present Protocol shall be executed. The Philippine Experience in Abolishing the Death Penalty; Commission on HumanRights; January 2007. °°FIDHis aninternational humanrights NGOfederating 184 organizations from | 12 countries. Since 1922, FIDH has been defendingall civil, political, economic, social and cultural rights as set out in the Universal Declaration of Human Rights. See: https://www.fidh.org/en/issues/death-penalty/goingbackwards-the-death-penalty-in-southeast-asia (accessed on 4 November2016) “Ibid. 8Article III, Section 19 (1), 1987 Philippine Constitution. 2 Article 26, Vienna Convention on the Lawof Treaties; Concluded at Vienna on 23 May 1969 “See: http://www. judicialmonitor.orarchive 0908/generalprinciples.html (accessed on 11 October 2016). 60