Justice Carpio recounts how Sandy Cay became a permanent island and was effectively seized by China in 2017, challenging official denials and highlighting the implications for Philippine territorial sovereignty in the West Philippine Sea.
Justice Carpio explains why Subi Reef—though a low‑tide feature—is within the Philippines’ territorial sea because it lies within 12 nautical miles of Pag‑asa Island under the 2016 South China Sea Arbitral Award.