because the United States is a federation of U.S. states and therefore a federation of jurisdictions. The agreement contains various procedural safeguards to protect rights to due process and proscribe double jeopardy.[VIII 2–6] The agreement also exempts Philippine personnel from visa formalities and guarantees expedited entry and exit processing;[IV] requires the U.S. to accept Philippine drivers licenses;[V] allows Philippine personnel to carry arms at U.S. military installations while on duty;[VI] provides personal tax exemptions and import/export duty exclusions for Philippine personnel;[X, XI] requires the U.S. to provide health care to Philippine personnel;[XIV] and exempts Philippine vehicles, vessels, and aircraft from landing or ports fees, navigation or overflight charges, road tolls or any other charges for the use of U.S. military installations.[XV] Incidents Subic rape accusation The U.S. has at least twice used the Agreement to keep accused military personnel under U.S. jurisdiction. On January 18, 2006, the U.S. military maintained custody of four troops accused of rape while visiting Subic Bay during their trial by a Philippine court. They were held by American officials at the United States Embassy in Manila. This led to protests by those who believe that the agreement is one-sided, prejudicial, and contrary to the sovereignty of the Philippines. The agreement has been characterized as granting immunity from prosecution to U.S. military personnel who commit crimes against Filipinos, and as treating Filipinos as second class citizens in their own country. As a result of these issues, in 2006, some members of the Philippine Congress considered terminating the VFA. However, the agreement was not changed. Death of Jennifer Laude A second Philippine court case under the VFA is the one following the death of Jennifer Laude, also involving a U.S. Navy ship docked at Subic Bay. This case happened after the Enhanced Defense Cooperation Agreement was signed. Supreme Court cases The constitutionality of the VFA was challenged twice. The case Bayan v. Zamora was dismissed on October 10, 2000, by the Supreme Court of the Philippines, sitting en banc. The second challenge, Suzette Nicolas y Sombilon Vs. Alberto Romulo, et al. / Jovito R. Salonga, et al. Vs. Daniel Smith, et al. / Bagong Alyansang Makabayan, et al. Vs. President Gloria Macapagal-Arroyo, et al. submitted on January 2, 2007, was decided on February 11, 2009, again by the Supreme Court sitting en banc. In deciding this second challenge, the court ruled 9–4 (with two justices inhibiting) that,