Treaty of Washington (1900) and "Convention regarding the boundary between the Philippine Archipelago and the State of North Borneo". Many analysts consider that the 1900 Treaty of Washington concerned only the islands of Sibutu and Cagayan de Sulu.,[47][48] but a point of view argued that Scarborough Shoal has been transferred to the United States based on the Treaty of Washington (1900),[49] ignoring the fact that the cession documents from the United States to the Philippines did not have any reference to the Scarborough Shoal[50]

The DFA asserts that the basis of Philippine sovereignty and jurisdiction over the rock features of Bajo de Masinloc are not premised on the cession by Spain of the Philippine archipelago to the United States under the Treaty of Paris, and argues that the matterJune 5 of that year, Domingo Siazon, who was then the Philippine Secretary of Foreign Affairs, testified in front of the Committee on Foreign Relations of the United States Senate that the Shoal was "a new issue on overlapping claims between the Philippines and China".[53]

Permanent Court of Arbitration tribunal ruling

In January 2013 the Philippines formally initiated arbitration proceedings against the PRC claim on the territories within the "nine-dash line" that include Scarborough Shoal, which the Philippines claimed is unlawful under the UNCLOS convention.[55] An arbitration tribunal was constituted under Annex VII of UNCLOS and it was decided[by whom?] in July 2013 that the Permanent Court of Arbitration (PCA) would function as registry and provide administrative duties in the proceedings.[56]

On 12 July 2016 the PCA tribunal agreed unanimously with