reasons” to re-impose death penalty. It follows uderstanding crimes” that the of the phrase should be narrowly, in the same international “heinous interpreted manner as the law interpretation of the phrase “the most Since, as shown Constitution must consistently domestic with serious crimes”. above, the be the read international legal obligations of the Philippines, the proposed limitation laws fail to comply with the within Constitution, grounds for Section providing their 19 of the additional rejection by Congress. 44