Department of Foreign Affairs (DFA) said Tuesday that the government submitted 12 volumes or over 3,000 pages supplemental documents to the five-member tribunal on March 16.
The submission answers 26 questions from the tribunal requesting for additional argument and information concerning the tribunal's jurisdiction on the matter and the merits of the Philippines' claims in the resource-rich region.
"The Philippines has submitted detailed responses and extensive additional information," the DFA said in a statement.
The questions also focused on the Philippines' challenge of China's nine-dash line, which appears on ancient Chinese maps and covers virtually the entire West Philippine Sea, including coastal and exclusive economic zones (EEZs) of neighboring countries.
The first volume has 200 pages of written argument while the second volume has a 200-page Atlas containing detailed information about 49 islands, reefs and other features in the West Philippine Sea.
China has expansion and reclamation activities in several reefs in the disputed waters--the latest of which are the Subi (Panganiban) and Mischief (Zamora) Reefs. Earlier, China expanded its activities into six other reefs--Fiery Cross (Kagitingan), Mabini (Johnson South), Malvar (Eldad), Calderon (Cuarteron), Burgos (Gaven) and Kennan (Hughes) Reefs.
These reclamation activities are not in the additional memorial submitted by the Philippines because they were not part of the 26 questions asked by the tribunal, although the Philippines is looking for an opportunity to raise the said issue.
Jose admitted that the reclamation activities can "adversely affect" the arbitration case" as these "are intended to alter the conditions on the ground and change the status quo."
But since the tribunal didn't ask specific questions about the reclamation, the Philippines "did not go that topic in great detail."
"If there will be an opportunity next time to raise it [reclamation issue], definitely. It would be good if the tribunal can look at the features themselves and see what were the original features there, and what will happen after the reclamation," Jose said.
"There's a great bearing [on the case] if there is alteration on the features and characters . . . if other are thinking that they would change the maritime entitlements, then that is something we should look into," he added.
Turning previously submerged features of the region into islands would extend China's or any other claimants' sovereignty and jurisdiction because of territorial and maritime entitlements such as exclusive economic zones and extended EEZs.
After this supplemental submission, China will also be given the time to submit their own arguments. But since China has already refused to participate in the arbitration, it is more likely that it would just let this requirement slide.
In July this year, the Philippines expects to be called for an oral argument. After that, the court will hand down the decision on the case in March 2016 with or without China's participation.
It might even take the court a shorter time to decide on the case because of China's non-participation, Jose said.
The supplemental memorial was a combined effort and coordination of relevant agencies, the Foreign Affairs department said.
"The Philippines appreciates the evident care and attention the tribunal is giving to the case, as reflected by the scope and detail of the tribunal’s questions," it added.
With "utmost professionalism," the tribunal managed to hurdle the difficulties created by China's decision not to appear or submit any of their arguments to the court.
"The Philippines is confident that its answers to the tribunal's questions leave no doubt that the tribunal has jurisdiction over the case and that the Philippines claims, including in particular its claims concerning the nine-dash line, are well-founded in fact and law," the statement said.
The West Philippine Sea is a region rich in mineral and oil deposits. More than $5 billion worth of global trade passed by it annually, making it one of the most vital sea routes in the world.
Beijing's expansive claims in the region has rocked the international community, who continues to call for a peaceful resolution to the disputes arising from the overlapping claims of China, Taiwan, the Philippines, Malaysia, Vietnam and Brunei Darussalam.
The Philippines decided to bring the matter before the tribunal in January 2013 shortly after the incident at the Scarborough Shoal where Chinese and Philippine naval ships staged a standoff for two months in mid-2012. (CVB/Sunnex)
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