Referring to military documents using similar wording, the Report on the Practice of the Philippines affirms the customary nature of Article 52(2) of the 1977 Additional Protocol I. 

According to the Soldier’s Rules (1989) of the Philippines, enemy combatants are military objectives. 

The Philippine Army Soldier’s Handbook on Human Rights and International Humanitarian Law (2006) notes in its glossary: “Civilian in military objective – A military objective remains a military objective even if civilian persons are in it. The civilian persons within such an objective or its immediate surroundings share the danger to which it is exposed.”