Philippines submits 3,000-page rebuttal vs China

Paterno R. Esmaquel II

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Philippines submits 3,000-page rebuttal vs China
(UPDATED) The Philippines says its supplemental memorial contains 'detailed responses' to the arbitral tribunal's questions based on China's claims

MANILA, Philippines (UPDATED) – The Philippines announced on Tuesday, March 17, that it has filed its rebuttal against China in a historic case over the West Philippine Sea (South China Sea). 

The Philippines on Monday, March 16, submitted its supplemental memorial to the arbitral tribunal handling the historic case at the Permanent Court of Arbitration.

In a media briefing on Tuesday, Philippine Department of Foreign Affairs (DFA) spokesman Charles Jose said the memorial is 3,000 pages long and contains “detailed responses” to the tribunal’s questions based on China’s claims.

“The Philippines is confident that its answers to the tribunal’s questions leave no doubt that the tribunal has jurisdiction over the case, and that the Philippine claims, including in particular its claims concerning the 9-dash line, are well-founded in fact and law,” DFA spokesman Charles Jose said.

The supplemental memorial came as the Philippines protests the artificial islands that China is building in the South China Sea. (READ: Philippines to UN: China reclamation destroys nature)

Jose said the Philippines “did not go into this topic in great detail,” and “cannot say to what extent we dealt on it.” He pointed out that China’s reclamation in the disputed waters “is a very recent development.”

The tribunal required the Philippines to submit the supplemental memorial after China publicized its position paper on the case in December 2014.

Through the position paper, China meant to address the 4,000-page memorial or pleading that the Philippines filed against China in March 2014. China published this paper a week before its deadline to respond to the Philippines’ memorial. 

China refused to file a counter-memorial.

The position paper is part of China’s legal strategy – to reject the arbitral proceedings yet to use media to argue against the Philippines.

Ensuring neither ‘is prejudiced’

In Tuesday’s media briefing, Jose explained that the tribunal’s questions “relate to issues concerning both the tribunal’s jurisdiction and the merits of the Philippines’ claims.

China argues that the tribunal, in the first place, has no jurisdiction over the case.

In its memorial in March 2014, the Philippines is tackling both jurisdiction over and the merits of the case. Parties in other arbitration proceedings “bifurcate” their cases, which means they separately tackle jurisdiction and merits.

“If you have a very strong case, you do not talk about jurisdiction. You go to straight to the case,” then Philippine Solicitor General Francis Jardeleza explained.

The Philippines, Jose said on Tuesday, “submitted detailed responses and extensive additional information” on both jurisdiction and merits.

The 12-volume, 3,000-page submission includes the following:

  • Volume 1 – 200 pages of written arguments

  • Volume 2 – 200-page atlas containing detailed information about 49 islands, reefs, and other features in the South China Sea 

“Preparing such an extensive submission in such short order required substantial effort and coordination from relevant concerned agencies,” Jose said.

He added: “The Philippines appreciates the evident care and attention the tribunal is giving to this case as reflected by the scope and detail of the tribunal’s questions. The tribunal has managed with utmost professionalism the difficulties created by China’s decision not to appear, taking care to make sure that neither side is prejudiced by that decision.” –

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Paterno R. Esmaquel II

Paterno R. Esmaquel II is a senior multimedia reporter covering religion for Rappler. He also teaches journalism at the University of Santo Tomas. For story ideas or feedback, email