Allies, however close their bilateral relations may be, will inevitably have disagreements and irritations in their relations. Manila and Washington can, however, address their differences through different channels. However, these challenges should not take advantage of the overall relationship and jeopardize their efforts in pursuing their common interests. The end of the VFA, which would be seen as a response to disputes on specific issues, does not address differences of opinion or the Philippines` national security interests service. The second challenge, Suzette Nicolas y Sombilon Vs. Alberto Romulo, et al. / Jovito R. Salonga, et al. Vs. Daniel Smith, et al. / Bagong Alyansang Makabayan, et al. Vs. President Gloria Macapagal-Arroyo, et al., on 2 January 2007, was re-decided by the Supreme Court on 11 February 2009.
In deciding this second challenge, Court 9-4 (with two judges who inhibit) ruled that “the Visiting Forces Agreement (VFA) concluded on February 10, 1998 between the Republic of the Philippines and the United States is in accordance with the Constitution … The decision continued, particularly with respect to the subic Rape case, “… the Romulo-Kenney agreements of 19 and 22 December 2006 are not in accordance with the VFA and the Minister of Foreign Affairs, respondent, is responsible for negotiating without delay with the representatives of the United States the corresponding agreement on detention centres under the Philippine authorities, in accordance with Article V, para. VFA, until the status quo is maintained until further decisions of the Court.  UP professor Harry Roque, an adviser to former Senator Jovito Salonga, one of the petitioners in the case, said in a telephone interview about the decision on the consistency of the VFA. “We`re going to appeal… We hope to be able to convince the other judges to join the four dissenters.  Despite this continuity, the VFA shutdown – and even its subsequent suspension – has created a cloud of uncertainty about the evolution of security relations with the Philippines` strategic/global partners. Without the VFA, it is difficult to understand how the annual exercises between the Philippines and the United States were carried out in similar proportions to those of previous years. In addition to capacity building, Balikan exercises also promote interoperability. It should be noted that balikatan appears to have moved from a bilateral exercise to an increasingly multilateral undertaking. Since 2012, Australia, Japan, Vietnam and a few other countries have participated in the Balikatans as observers.  After the Philippine Senate`s compliance with the Australo-Philippine VFA in 2012, Canberra became a real participant in Balikatan.
 Without the Philippine VFA, the future of balikate – which strengthens not only cooperation between Manila and Washington, but also like-minded partners – is very uncertain. “While the VFA is a bilateral agreement between the Philippines and the United States, it can have an impact on how other countries allied with the United States and/or favorable to the United States .- it may have an impact. B for example, Japan, Australia, South Korea, Singapore and Israel – perceive and/or conduct their external relations with the Philippines, it should be decided to terminate the agreement.  Rappler, “FULL TEXT: Locsin on impact assessment of VFA termination,” Rappler, Ferbruary 6, 2020, www.rappler.com/nation/251198-full-text-locsin-speech-impact-assessment-visiting-forces-agreement-termination (available July 13, 2020).