Senate—a compact negotiated and proclaimed under the authority of the President— was a “treaty” within the meaning of domestic law.23 It follows that it is not possible to identify any fundamental internal law of the Philippines that was offended or violated by the ratification of the Second Optional Protocol. In any event, the suggestion that any failure to comply with the internal law of the Philippines was “manifest” is untenable. For a rule of internal law to be manifest within the meaning of Article 46, it must be a rule that is notorious or “objectively evident” to the external community of States. The circumstances in which the Second Optional Protocol was ratified do not raise any manifestly obvious, notorious, or objectively evident rule of the law of the Philippines. On the contrary, for the reasons given above, the case law of the Supreme Court of the Philippines deny the existence of any rule that would affect the validity of ratification within the Philippines legal system. Any argument raised in international law under Article 46 of the Vienna Convention on the Law of Treaties would fail. The Second Optional Protocol is a binding treaty commitment of the Philippines as a matter of public international law. A change in government does not permit withdrawal from the Second Optional Protocol. 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. A subsequent change of government does not affect that position. One of the fundamental features of the international legal system that provides stability and security is the understanding among States that a change in government does not affect existing treaty obligations. In other words, a treaty, once signed and ratified by a State, binds that State in accordance with the rules of international law whether or not the government of that state changes in the future. The alternative model, by which States are free to renegotiate international terms on every change of government, is plainly unworkable and would destroy the fabric of the rules-based system of international law – a rules-based system that middle powers, such as the Philippines, rely upon for security and prosperity. The VCLT is instructive in this situation. It provides that: 1. A treaty which contains no provision regarding its termination and which does not provide for denunciation or withdrawal is not subject to denunciation or withdrawal unless: it is established that the parties intended to admit the possibility of 23 United States v. Belmont, 301 U.S. 324 (1937). Page 9 of 23

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