evidence: The Philippines claims the northeastern section of the Spratly Islands as the Kalayaan Island Group, in addition to the Scarborough Shoal, which it calls the Bajo de Masinloc. Malaysia claims part of the Kalayaan Island, while China and Taiwan claim the entirety of the island group. China and Taiwan also claim the Scarborough Shoal, which is currently patrolled by Chinese maritime law enforcement vessels. In addition, the body of water enclosed within the nine-dash line promulgated by China and Taiwan overlaps with the Philippines’ exclusive economic zone (EEZ) and continental shelf. [...] The Philippines claims the Kalayaan Island Group on the assumption that after Japan renounced its title to the islands in the San Francisco Treaty of Peace of 1951, they reverted to being terra nullius because title was not explicitly passed to another state. Therefore, when a Filipino explorer named Tomas Cloma declared ownership over 33 maritime features in the Spratly Islands in 1956, no other country had a valid claim to them. In 1978, the administration of President Ferdinand Marco issued a decree that listed three bases for the Philippines’ legitimate rights to the territory: contiguity with the Philippine archipelago, historical title, and the lapsing of others’ claims. Following the passage in March 2009 of a legislative act to bring the Philippines’ baselines in conformity with the 1982 UN Convention on the Law of the Sea, the Philippines’ claim to territorial waters around the maritime features of the Kalayaan Island Group appears to have been restricted to using the low-water baseline, therefore precluding the treatment of the islands as an archipelagic group.