evidence: A draft framework for the envisioned federal constitution proposes the inclusion in Philippine territory of Sabah, specifically that part which belongs to the Sultanate of Sulu — a thalassocracy founded in 1405. Sabah’s inclusion is being pushed based on historical fact. But the history of Sabah in the Philippine context might not be on our side sovereignty-wise. [...] The cession of claim over Sabah by the Sultan’s heirs in 1962 to the Philippine government amounted only to a transfer of proprietary claim. The heirs could not transfer sovereignty or territorial claim over Sabah. Thus, Philippine territory under a federal constitution cannot be greater than that acquired under the Treaty of Paris. The Sabah claim can perhaps be best understood if it is bifurcated in separate issues — territorial or sovereignty on one hand, and proprietary on the other. The first is tenuous; the second is formidable. A strong lobby before the British Crown would be equally important to rectify the injustice wrought upon the Sultan of Sulu by the Cession Order of 1946. After all, the greatness of a king lies not in his power but in his capacity to be the fountainhead of justice.