The other case, United States of America/ Pink,55 also participated in the award of Litvinov. The U.S. Supreme Court here reiterated its ruling in the Belmont case and found that Litvinov`s mission is an international pact or a treaty-like agreement under the predominance clause of the U.S. Constitution.56 „It is good that the Philippine government has the right to do so if it finds that the agreement no longer corresponds to our national interest.“ Although Duterte did not threaten to withdraw from the MDT and EDCA, both would still be affected. Without the VFA, for example, joint training exercises would only be limited to „agreed sites“ under the EDCA, Bagares said. This would also have an impact on the VFA intercom agreement, he added. (c) a specific directive on the importation and export of U.S. government equipment, materials, supplies and other goods imported or acquired in the Philippines by or on behalf of the United States Armed Forces in the course of activities covered by the agreement; And as the rp-US basic agreement expired in 1991, the Philippines and the United States negotiated a possible extension of the basic military agreement. On 16 September 1991, the Philippine Senate rejected the proposed PR-US Treaty on Friendship, Cooperation and Security, which would have extended the presence of US military bases in the Philippines2. Despite this, defence and security relations between the Philippines and the United States of America continued in accordance with the Mutual Defence Treaty. The VFA was signed in February 1998 under the mandate of Fidel V. Ramos, then President, followed in October by a counter-agreement on Filipino personnel who visited the United States.
It was ratified shortly thereafter by President Joseph „Erap“ Estrada, who succeeded Ramos, and officially entered into force in June 1999, after approval by the Philippine Senate.