evidence: First, since Second Thomas Shoal has never been the Philippines’ territory, the MDT cannot be applied under the territorial jurisdiction principle. Pursuant to Article I of its 1935 constitution, the Philippines’ territory is defined by a series of international treaties, including the 1898 treaty between the US and Spain (the Treaty of Paris), the 1900 treaty between the US and Spain for the cession of outlying islands of the Philippines (the Treaty of Washington), and the 1930 convention between the UK and the US regarding the boundary between the state of North Borneo and the Philippine archipelago.