Learning & Education
Date of Award: 4 April 1928
By virtue of the Treaty of Peace of 10 December 1898, Spain ceded the Philippine Islands to the United States. This archipelago of Philippines included a small island named Island of Palmas (or Miangas), located between the archipelago of the Philippines and the Dutch East Indies. In 1899, the Treaty of Paris was notified to the Netherlands, which did not make any observations as to the delimitation of the Philippines. In 1906, an official of the United States paid a visit to the island which led to the conclusion that the island was considered by the Netherlands as forming part of the territory of its possessions. The United States informed the Netherlands by diplomatic correspondence that the United States claimed sovereignty over the island based on the cession by Spain. The Dutch Government also claimed sovereignty of the island on the basis of having exercised sovereignty there for more than 200 years. They could not reach an agreement and the Parties agreed to submit the claims to an arbitral tribunal composed of a sole arbitrator.
The Island of Palmas Case (or Miangas): Award