GRP-milf MEMORANDUM OF AGREEMENT

Constitutionality Issues

Submitted by: Adrid, Michael Angelo Azarcon, Ayn Ruth Limcolioc, Louie Mark Roaldo, Miguel Felipe Villalobos, Angeli Submitted to: Atty. Ulpiano Sarmiento III August 26, 2008

GRP-MILF MEMORANDUM OF AGREEMENT

Constitutionality Issues
A comprehensive peace has eluded us for half a century.

But last night differences on the tough issue of ancestral domain were resolved. Pres. Gloria Macapagal-Arroyo, State of the Nation Address 2008

The Philippines, for a long time, has been burdened with internal conflicts in Mindanao. There have been a few talks to reach a conclusive solution towards peace, and to provide a means towards progress for the people in Mindanao. Since the 1960's, it has not enjoyed a semblance of relative peace. All efforts to arrive at a reasonable settlement to bring about the peace in the region have all been futile to say at the very least. Up to the present, as both parties continue with their indecisiveness and insincerity towards reaching a conclusion to this age-long battle, it has been to the detriment of the people of Mindanao ultimately resulting to casualties and the incurable fear of the people who reside within. The Neverending Quest for the Elusive Peace Peace talks between the government (GRP) and the Moro Islamic Liberation Front (MILF) began in 1996. Ceasefires were broken resulting to the attack of the MILF fighters headed by the commanders to the Armed Forces of the Philippines (AFP) units, bombed or raided villages and killed residents and soldiers. On September 2 1996, the GRP-Moro National Liberation Front (MNLF) Final Peace Agreement was signed. It was followed by forming a brand new negotiating panel during the Ramos administration. But, both were disapproved by the MILF central leadership. The MILF leaders still stand to be independent from the Filipino state. In early 1997, the GRP and MILF panels issued a joint statement for peace. Transgressions between the MILF and AFP continued until the AFP launched their biggest offense in June. In 1999, formal peace talks began and both panels agreed on the rules and procedures on how it will be conducted. Soliman Santos, who documented the history of the MILF peace process, noted that from 1996 to 2000 the government and the MILF entered into a total of 39 agreements, joint communiqus, acknowledgments, and resolutions, 16 agreements on the implementation of the ceasefire pact, 13 on the framework of the talks, 6 on procedural matters, and 4 on recognition and verification of MILF camps. When President Estrada was in command, he declared an all out war policy and issued warrants of arrest against the MILF leaders and commanders in response to raids, attacks and takeover of new territory by MILF despite of the so-called peace talks. The declaration suspended the peace process and resulted on the shot back declaration of MILF Chairman Salamat Hashim of jihad against the Philippine government. Macapagal-Arroyos assumption of the presidency paved the way for the resumption of the MILF peace talks. This has led to the present Memorandum of Agreement-Ancestral Domain (MOA-AD). Since the MILF is the main instigator in the rebellion in Mindanao, the MOA's goal is to apportion power to the Bangsamoro people who are the Muslim natives of Mindanao. In the efforts to make peace with the MILF, the government's peace panel negotiated with them and came up with the recent terms of the MOA.

Facts of the Case

On August 2008--headlines of various newspapers made known to public a Memorandum of Agreement that was negotiated between the Philippine Government and the MILF. The agreements draft proposed of

a so-called Bangsamoro Juridical Entity (BJE) which would literally dismember the national territory of the Philippines contrary to its delineation in the 1987 Constitution of the Philippines.

This BJE shall be comprised of the present ARMM together with six municipalities of Lanao del Sur, namely: Baloi, Munai, Nunungan, Pantar, Tagoloan and Tangkal. Under the MOA, the Bangsamoro territory comprises the following areas: the present ARMM; the municipalities of Baloi, Munai, Nunungan, Pantar, Tagoloan and Tangkal in Lanao del Norte Province (which voted for inclusion in the ARMM during the 2001 plebiscite); and the additional geographic areas in the provinces of Sultan Kudarat, Lanao del Norte and North Cotabato, all of which are still subject to plebiscite. North Cotabato was also among the provinces included in the expanded ARMM, to be governed by the BJE; as well as eight barangays in Zamboanga City, including the entire downtown area of the city, the City Hall, a cathedral and the Ateneo de Zamboanga University. On top of the aforementioned provinces, regions and areas in Mindanao, certain parts of Palawan were to be included.1

The Proposed Bangsamoro Juridical Entity The GRP-MILF MOA The MOA (see appendix A) contains general principles concerning the Bangsamoro identity and their rights. It also provides the establishment of a system of government appropriate for them, their territorial domains where they can exercise jurisdiction, and the protection and utilization of resources found therein. The said agreement is divided into five parts. The first part which is entitled Terms of References invoked past agreements between the government and the MILF leading to the creation of the said treaty. The second part Concepts and Principles manifests the acknowledgement of the parties relating to the claim of the Moros to their ancestral domains, their right to self-governance, mutual respect to one's identity, and that the Bangsamoro Juridical Entity (BJE) shall have the authority and jurisdiction over the

Ancestral Domain and Ancestral lands as well as the delineation of ancestral domains of the Bangsamoro located therein. The third part Territory defines the land mass as well as the maritime which includes: Mindanao-SuluPalawan geographic region and the expansion of their territory to an extent, it also includes the terrestrial, fluvial, alluvial domains, and the aerial domain also covering their jurisdiction on activities conducted therein. It is stipulated in this section that the parties must commit themselves to the full mutual implementation of the framework agreement on territory and that a plebiscite will be conducted covering the areas enumerated in the agreement. The fourth part Resources empowers the BJE with authority and responsibility for the land use, development, conservation and disposition of the natural resources within the homeland in order to reinforce their economic self-sufficiency. Lastly, the last part Government provides for an associative relationship between the Central Government and the BJE which is characterized by shared authority and responsibility with a structure of governance based on executive, legislative, judicial and administrative institutions with defined powers and functions in the Comprehensive Compact.

The Foiled Signing of the Agreement The MOA inevitably raised some eyebrows due to the fact that the deliberations toward the drafting of the MOA was made known to the public only up until a few days prior to the signing of the agreement in Kuala Lumpur last August 5. This gave rise to upheaval of the masses especially the residents of the provinces embraced in the delineated territory. Because of the secrecy of the agreement, some of these provinces complained that they were not duly consulted with regard to their inclusion in the separate Bangsamoro region. Senator Mar Roxas, in reaction to this controversy, immediately filed a motion at the Supreme Court to suspend the signing of the MOA alleging the constitutional infirmities of the agreement. Consequently, the Court issued a Temporary Restraining Order (TRO) to suspend the scheduled signing of the agreement on account of unconstitutionality. The public was in shock primarily because the negotiations behind this agreement was all done in full secrecy. In defense, the government invoked the Principle of Executive Privilege anchoring on the reason that it was to protect the country for military, national security and diplomatic concerns.

Legal Issues
While it is true that the case is not yet ripe for adjudication, it is of transcendental importance to look into the constitutionality of the initial draft of the foiled Memorandum of Agreement between the Philippine Government and the Moro Islamic Liberation Front.

1. Whether or not the proposed territory of the Bangsamoro Juridical Entity was a direct violation of the National Territory of the Philippines. 2. Whether or not the Philippine Government was in a position to enter into an agreement which would entail the amendment of the Constitution. 3. Whether or not the Memorandum of Agreement was an Abuse of Police Power on the part of the government.

4. Whether or not there was sufficient grounds for the Philippine Government to invoke Executive Privilege to justify the secrecy behind the negotiations. 5. Whether or not the MILF was in a position to state in the agreement that they will be exercising certain powers supposedly vested in the President of the Philippines alone. 6. Whether or not, on top of the more prominent provisions lifted from the Constitution, the MILFMOA also violates the Declaration of the Principles and State Policies. 7. Whether or not it was necessary for the MOA draft to make reference to our Constitution in stating the number of proposals found therein.

To sum it all up, the primary issue in this case is: Whether or not the GRP-MILF MOA was constitutional.

Rule of Law
I. The 1987 Constitution of the Philippines: 2. Article I: Declaration of Principles and State Policies 3. Article II: National Territory 4. Article III: Bill of Rights 5. Articles VI, VII and VIII: Constitution of Government and, 6. The Presidents Exclusive Powers 7. Article X: The Enumerated Powers of the Autonomous Regions 8. The Amendatory Process of the Constitution 9. Necessity of Making Reference to the Constitution 10. Unlawful Delegation of Powers enshrined in Article XII of the Constitution

II. Executive Order 464: Executive Privilege

Reasoning
THE NATIONAL TERRITORY OF THE PHILIPPINES The pertinent provisions in the MOA read as:
The Parties concede that the ultimate objective of entrenching the Bangsamoro homeland as a territorial space is to secure their identity and posterity, to protect their property rights and

resources as well as to establish a system of governance suitable and acceptable to them as distinct dominant people.

Both Parties agree that the Bangsamoro Juridical Entity (BJE) shall have the authority and jurisdiction over the Ancestral Domain and Ancestral lands, including both alienable and non-alienable lands encompassed within their homeland and ancestral history, as well as the delineation of ancestral domain/lands of the Bangsamoro people located therein.2

The MILF-MOA, granting the formation of a so-called Bangsamoro Juridical Entity, gives consent to a formal and voluntary dismemberment of the Republic. The MOA places partitions in our national territory within that delineated in our Constitution based on the Treaty of Paris. According to Article I of the 1987 Constitution of the Philippines:

The national territory comprises the Philippine archipelago, with all the islands and waters embraced therein, and all other territories over which the Philippines has sovereignty or jurisdiction, consisting of its terrestrial, fluvial, and aerial domains, including its territorial sea, the seabed, the subsoil, the insular shelves and other submarine areas. The waters around, between, and connecting the islands of the archipelago, regardless of their breadth and dimensions, form part of the internal waters of the Philippines.

Based on the territory that is clearly covered by the Republic of the Philippines, the initial draft of the MOA clearly renounces the Philippines vested claim over the said ancestral lands by saying explicitly that they do not form part of the public domain. The full exploitation of the resources found therein, in addition to the power to regulate all affairs and functions that may arise from it without any suggestion at the very least of the Philippines control over them is not just merely expanding their autonomy but rather giving them full autonomy. The inclusion of the provision on National Territory of the Philippines in the 1987 Constitution is for the purpose of providing a clear determination of the territory over which the Philippines shall be exercising full and exclusive authority. By stipulating that a considerable area within this territory will be given up to the control of an entity other than the Government of the Philippines is, in effect, ceding said territories to the MILF.

UNLAWFUL DELEGATION OF POWERS ENSHRINED IN ARTICLE XII OF THE CONSTITUTION Under the regalian doctrine, public domain--except for those that may be alienated--shall be under the ownership of the State. This is in order to prevent any excessive usurpation and concentration of national wealth among a small fraction of the populace. Hence, Section 2 of Article XII of the 1987 Constitution states that:

All lands of the public domain, waters, minerals, coal, petroleum and other mineral oils, all forces of potential energy, fisheries, forests or timber, wildlife, flora and fauna, and other natural resources, are owned by the State.3

The MOA grants to the BJE the exclusive power of control to exploit the resources found within the territory ceded to them by the agreement. Among the pertinent provisions are:
The Bangsamoro Juridical Entity (BJE) shall have jurisdiction over the management, conservation, development, protection, utilization and disposition of all natural resources, living and non-living, within its internal waters extending fifteen (15) kilometers from the coastline of the BJE area. The Bangsamoro People through their appropriate juridical entity shall, among others, exercise power or authority over the natural resources within its territorial jurisdiction:

1. To explore, exploit, use or utilize and develop their ancestral domain and ancestral lands
within their territorial jurisdiction, inclusive of their right of occupation, possession, conservation, and exploitation of all natural resources found therein; 2. Jurisdiction and control over, and the right of exploring for, exploiting, producing and obtaining all potential sources of energy, petroleum, in situ, fossil fuel, mineral oil and natural gas, whether onshore or offshore, is vested in the Bangsamoro juridical entity as the party having control within its territorial jurisdiction, provided that in times of national emergency, when public interest so requires, the Central Government may, during the emergency, for a fixed period and under reasonable terms as may be agreed by both Parties, temporarily assume or direct the operations of such strategic resources.

In addition to the constitutional provision above, the same fundamental law also provides that only agricultural lands are alienable.4 The lands to be ceded by the MOA to the BJE include not only the agricultural lands found within the territory in question, but also mineral lands, water resources and, forest lands. Moreover, Section 2 of Article XII of the Constitution says that the exploration, development, and utilization of natural resources shall be under the full control and supervision of the State. The State may directly undertake such activities, or it may enter into co-production, joint venture,, or production sharing agreements with Filipino Citizens or corporations whose sixty percentum of capital is owned by Filipino citizens. The MOA contemplates of a shared control set-up between the Government of the Philippines and the BJE in so far as the resources found on the territory are concerned. A provision in the MOA reads as below:
h. Sharing of Minerals on Territorial Waters:

Consistent with paragraphs 5 and 6 of the provisions on Resources, all potential sources of energy, petroleum in situ, hydrocarbon, natural gas and other minerals, including deposits or fields found within the territorial waters, shall be shared between the Central Government and the BJE in favor of the latter through production sharing agreement or economic cooperative agreement.5
A prejudicial question is thus presented. What is the legal status of the BJE? Can it be considered as a Filipino citizen or a Filipino corporation? The identity of the Bangsamoro people can be gleaned upon on the first declaration in the MOA. It says that:

1. It is the birthright of all Moros and all Indigenous peoples of Mindanao to identify themselves and be accepted as Bangsamoros. The Bangsamoro people refers to those who are natives or original inhabitants of Mindanao and its adjacent islands including Palawan and the Sulu archipelago at the time of conquest or colonization of its descendants whether mixed or of full blood. Spouses and their descendants are classified as Bangsamoro. The freedom of choice of the Indigenous people shall be respected. 2. It is essential to lay the foundation of the Bangsamoro homeland in order to address the Bangsamoro peoples humanitarian and economic needs as well as their political aspirations. Such territorial jurisdictions and geographic areas being the natural wealth and patrimony represent the social, cultural and political identity and pride of all the Bangsamoro people. Ownership of the homeland is vested exclusively in them by virtue of their prior rights of occupation that had inhered in them as sizeable bodies of people, delimited by their ancestors since time immemorial, and being the first politically organized dominant occupants. 6

This is a clear renunciation of any association with the Philippines by the BJE with regard to the question of citizenship. It can be seen that they wish to be identified as Bangsamoro people and not Filipino citizens. With this declaration, they are placing themselves in a position to be qualified to enter along with the Philippines, joint agreements for exploitation of natural resources found within the territory in question.

THE CONSTITUTION OF GOVERNMENT & AUTONOMOUS REGIONS In furtherance to the wave of powers given to the BJE to effect their full autonomy, a provision in the MOA states:

4. The Bangsamoro juridical entity is free to enter into any economic cooperation and trade relations with foreign countries: provided, however, that such relationships and understandings do not include aggression against the Government of the Republic of the Philippines; provided, further that it shall remain the duty and obligation of the Central Government to take charge of external defense. Without prejudice to the right of the Bangsamoro juridical entity to enter into agreement and environmental cooperation with any friendly country affecting its jurisdiction, 7

Under this, the BJE is empowered to enter into treaties and other international agreements. Moreover, the MOA places the entity on a protectorate status under the RP during the transition phase. This is in diplomatic missions that have yet to recognize the BJE. By having the Philippines introduce them, this could potentially flourish into their recognition. This clearly violates the exclusive authority of the President to enter into treaties. Moreover, no mention has been made regarding the lawful ratification of said treaties as prescribed by the Constitution. It is deemed that the BJEs concurrence to the terms of any international agreement it enters into, is sufficient for it to be binding upon them. According to the Constitution:

Section 21. No treaty or international agreement shall be valid and effective unless concurred in by at least two-thirds of all the Members of the Senate. 8

This provision provides for a system of checks and balance in the three-fold set-up of the Philippine Government. Hence, it cannot be disposed with. Without Senate concurrence, ratification of such treaties entered into by the BJE shall be unconstitutional. In addition, the Constitution only allows for a government set-up consisting of the Executive, Legislative, Judiciary, the Local Government and the Autonomous Regions. Their powers are all enumerated with any power expanding what has been enumerated expected to remain germane to what was specified. The power given to the Juridical Entity is not provided for in the enumerated powers even for Autonomous Regions. No acceptable construction can be made allowing for these powers without violating the precise text and intention of the Constitution.

THE ENUMERATED POWERS OF THE AUTONOMOUS REGIONS The Autonomous Region of Muslim Mindanao (ARMM) is, by far, the only autonomous region allowed for by the 1987 Constitution. The powers of this Autonomous Region is limited in so far as there is an enumeration of the powers that they can exercise. Thus, prior to the effecting of the ARMM, the Organic Act of 1989 for the ARMM has been enacted. This is in compliance with the constitutional provisions that say:
Section 17. All powers, functions, and responsibilities not granted by this Constitution or by law to the autonomous regions shall be vested in the National Government.

Section 18. The Congress shall enact an organic act for each autonomous region with the assistance and participation of the regional consultative commission composed of representatives appointed by the President from a list of nominees from multi-sectoral bodies. The organic act shall define the basic structure of government for the region consisting of the executive department and legislative assembly, both of which shall be elective and representative of the constituent political units. The organic acts shall likewise provide for special courts with personal, family, and property law jurisdiction consistent with the provisions of this Constitution and national laws. 9
In explaining the excluded powers from the ARMM, the highly esteemed constitutional expert, Father Joaquin Bernas, said that:

Those matters that are not covered in by the Organic Act are governed by the Revised Administrative Code. These matters are: (a) foreign affairs; (b) national defense; (c) postal service; (d) coinage and fiscal and monetary policies; (e) administration of justice; (f) customs and tarriff; (j) general auditing, civil service, elections10
Under the MOA, the BJE is granted with expanded powers that are not found within the original mandate of the ARMM Organic Act. The MOA says that:

8. The parties agree that the BJE shall be empowered to build, develop and maintain its own institutions, inclusive of, civil service, electoral, financial and banking, education, legislation, legal, economic, and police and internal security force, judicial system and correctional institutions, necessary for

developing a progressive Bangsamoro society the details of which shall be discussed in the negotiation of the comprehensive compact.11
Matters such as the institution of civil service, elections, fiscal and monetary policies, etc are devolved to the BJE by virtue of the MOA. This is a clear departure from what has been enumerated for the ARMM to exercise.

THE CHIEF EXECUTIVES EXCLUSIVE POWERS On the other hand, the MOA gives to the BJE the exclusive exercise of Executive Powers within their territory. This contravenes another constitutional provision stating that:

The executive power shall be vested in the President of the Philippines.12

The Executive power shall rest on the President of the Philippines. Any delegation of this powers, whether enumerated or residual, should still be within the effective control of the President. The MOA is silent on the Executives role on the powers delegated unto them. It is purely indicative that said powers will be within their sole right to dispose of without any mechanism for accountability drawing back to the greater Philippine State. Finally, the faulty process of arriving at the terms of the MOA places the Chief Executive under a dark light. The President is bound to observe the laws of the land as prescribed by the provision to wit:
The President shall have control of all the executive departments, bureaus, and offices. He shall ensure that the laws be faithfully executed. 13

The mere concurrence in the deliberations for an act, which violates the Constitution, gives the President with no power to do so.

LIMITS ON EXECUTIVE PRIVILEGE President Gloria Macapagal-Arroyo issued Executive Order 464 (see appendix B) granting to herself (and to her immediate subordinates under her office, by her orders) the privilege of either refusal to speak, to appear before investigative bodies, or to disclose certain information to the public in cases that are enumerated in the said order. According to Father Bernas there are three types of Executive Privilege14:

1) The privilege to keep State secrets in order to prevent disclosure of information that could
subvert military or diplomatic objectives; 2) The Law of Evidence to withhold from disclosure the identity of persons who furnish information of violations of law to officers charged with enforcement of that law, and; 3) The privilege that attaches to opinions, recommendations, and deliberations which comprise the process of arriving at presidential decisions.

There must be a clear definition of the military, national security and diplomatic concerns involved which was the basis of the secrecy in the negotiations. In the absence of a sufficient definition, which would satisfy the people, the executive privilege cannot be adequately invoked. Moreover, the territorial integrity supersedes the purported national security issues which should only revolve around settlement of disputes through concessions that the government has the power to give. The cessation of territory is not a bargaining chip allowed by the Constitution. In pursuant to the transcendental importance of this act, a review of this invocation is necessary.

DECLARATION OF PRINCIPLES AND STATE POLICIES Article II, Section 22 of the 1987 Constitution says
The State recognizes and promotes the rights of indigenous cultural communities within the framework of national unity and development.

This is the principle of pursuing an enabling policy for the conservation of rights of the indigenous people under the framework of national UNITY and government. A policy of full autonomy shall not promise of national unity given its violations of the fundamental law of the land. Moreover, it also alienates non-indigenous inhabitants of the territory in question who have already been fully integrated in the Philippines. Furthermore, another State policy has been violated by the MOA in Article 2, Section 7 which states that:
The State shall pursue an independent foreign policy. In its relations with other states, the paramount consideration shall be national sovereignty, territorial integrity, national interest, and the right to self-determination.

A foreign policy should bear the States commitment to preserve the territorial integrity of the country. That in mind, any agreement whether foreign or local should espouse this principle as well.

THE NECESSITY OF MAKING REFERENCE TO THE CONSTITUTION The power of the President to negotiate is governed by the principles enshrined in the Constitution. Any deviation from these will tantamount to culpable violation of the fundamental law. It cannot be even argued that the capacity of the President to fix nor agree to these terms is consistent with the principles that have been laid. For this MOA to take effect, constitutional amendment has to be done so as to justify the execution of the terms therein laid.

AMENDATORY PROCESS OF THE CONSTITUTION The creation of a federal state entails massive revisions in the fundamental law. Only the people in their sovereign capacity can create such a state via amendment of the Constitution. The 1987 Philippine Constitution contemplates of a Philippine Territory clearly delineated, with a centralized government endowed with the power to govern all matters necessary for its continuous functioning. All returns and

consequences derived from said exercise of governance shall be disbursed only by the national government in equal appropriations and distributions across the entire country. Nowhere has the suggestion of sharing of powers ever been included in the text of the Constitution. This is for a recognition of a different form of government and nothing can enable this other than Constitutional amendment.

THE BILL OF RIGHTS vs. ABUSE OF POLICE POWER The rights of the people are well enshrined in the Constitution. Further, the Bill of Rights explicitly gives protection from abuse and the governments use of its tremendous police power cannot just be allowed to trample on these. As stated in Section 1 of Article III:
No person shall be deprived of life, liberty or property without due process of law, nor shall any person be denied the equal protection of the laws.

There was an unjustified secrecy in the negotiations between the government and the MILF before the signing of the MOA was announced openly--and this raised suspicions. Negotiations were being done at the expense of the filipino people which consequently brought about a direct violation of the peoples right to information, the right to due process and the right to participate in the decision-making process.15 The people residing in the alleged ancestral domains--muslims and christians alike--are mostly well integrated in the Philippine society. Even if it were to be assumed, in arguendo, that all of them concede to such a set-up, it cannot be justified for consultations have not been properly commenced. The news of the MOA just sprung up out of nowhere with a clear intent to mislead the people.

Position
The pacific settlement of the age-long dispute in Mindanao is a call not only a few have taken heed of. Unfortunately, they are motivated not by a genuine intent of effecting peace in the region, but rather by their selfish political considerations. While the idea of providing the region with an expanded autonomy, to enable them to exercise their right to self-determination, remain to be a positive yearning towards the attainment of justice, it should not be used as a deceptive facade to lure the people into thinking that their needs are being responded to. Hence, while the objective of the MOA may seem to be good, there should be a critical review of its terms so as to avoid the conflicts of rights. As this could be a cumbersome task, the actions of our leaders should strongly be anchored on a sincere resolve to really reconcile the differences between the people of Mindanao and the government. Only through this can the government be able to be assured of the commitment of the moros to truly cooperate and to finally put to an end this crisis.

1 Diaz, Patricio. MindaNews. More Road Blocks: Plebiscite. 12 August 2008. 2 GRP-MILF MOA: Concepts and Principles, Paragraph 4 and 6. 3 Article XII. Section 2. 1987 Constitution of the Philippines. 4 Article XII. Section 3. 1987 Constitution of the Philippines. 5 GRP-MILF MOA, Territory, Paragraph 2. 6 GRP-MILF MOA, Concepts and Principles, Paragraph 1 and 2. 7 GRP-MILF MOA: Resources, Paragraph 4. 8 Article VII. Section 21. 1987 Constitution of the Philipppines.

9 Article X, Sec 17 and 18, 1987 Constitution of the Philippines. 10 Bernas, Joaquin G. A Commentary on the 1987 Philippine Constitution. page 1103. 11 GRP-MILF MOA. Governance, Paragraph 8. 12 Article VII. Section 1. 1987 Constitution of the Philippines. 13 Article VII. Section 17. 1987 Constitution of the Philippines. 14 Bernas, Joaquin G. Constitutional Structure and Powers of Government: Notes and Cases Part I, 2nd Ed.. 1997. 15 Article III. Sections 1 and 7. 1987 Constitution of the Philippines.

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