the Government of the Philippines, The President of the Philippines Memorandum Circular 162… (2008)
“ WHEREAS, by virtue of Article 1 of the 1987 Philippine Constitution on National Territory, the Philippines has historical and legal right over certain parts of North Borneo (Sabah) ; WHEREAS, it is in the national interest to safeguard the country’s historical and legal right in North Borneo (Sabah) ; WHEREAS, the Philippines believes in the peaceful resolution of disputes with neighboring countries as provided under the same Constitution, which expressly states that the Philippines adheres to the policy of peace, equality, justice, freedom, cooperation, and amity with all nations ”
