Imagine a small island at the northern edge of the Nusantara that lies much closer to the Philippines. Miangas is only about 50 miles from Mindanao. At first glance, it would be easy to assume that the island should belong to the Philippines.
That assumption was once made officially. When Spain ceded the Philippines to the United States in 1898, the US considered Miangas, known as Palmas Island in the dispute, to be part of the territory it had acquired.
The Netherlands had a different claim. The dispute was eventually brought to international arbitration. On April 4, 1928, a Swiss arbitrator named Max Huber ruled that the entire island of Palmas belonged to the Netherlands.
So why did an island closer to the Philippines end up with the Netherlands, whose territory would later become part of Indonesia?
The answer lies in a history that goes far beyond the distance between the two islands.
Spain Discovered the Island, but Did Not Prove It Controlled It
The United States had a basis for its claim. During the case, it presented Spanish voyage records mentioning the area as early as 1526. European maps from the late 16th century also carried names such as “Palmas”, “Polanas”, and “Palmeiras” around the location of the island.
This suggested that European sailors may have known about Miangas since the 16th century. The problem was that there was not enough evidence that Spain had later occupied the island or established any form of administration there.
This mattered because the United States had acquired the Philippines from Spain in 1898. If Spain had held a valid claim to Miangas, the US argued that the right had passed to it along with the Philippines.
But when Leonard Wood, then Governor of the Moro Province, visited Miangas in 1906, he found Dutch flags flying on the shore and on a boat. The discovery made the competing Dutch claim much harder to ignore.
The Netherlands Pointed to Miangas’ Ties to Tabukan
The Dutch claim was based on something different. They did not argue that they had discovered Miangas first.
Since the 17th century, the Dutch East India Company, or VOC, had maintained political relations with Tabukan, a kingdom on Sangihe Island. The VOC and Tabukan signed agreements in 1677 and 1697. Over time, Miangas was identified as one of the islands under Tabukan’s authority.
An important clue appeared in 1700. The VOC sent ships in search of an island known as “Meangis”, a name used by the English sailor William Dampier. The expedition later sighted an island in November and landed there on December 9 and 10.
The people on the island flew the flag of their ruler. They also presented a document stating their allegiance to the King of Tabukan. The document was later lost, but Huber considered the island visited by the VOC expedition very likely to have been Palmas, or Miangas.
Another piece of evidence appeared in 1701. Rules that applied in Tabukan were also extended to an island called “Meamgy”. A report from the Governor of Ternate in 1706 later described Miangas as the northernmost territory under Tabukan and Taruna.
The Dutch case, therefore, was not that VOC ships were constantly present on Miangas. It was that a series of records showed the island being treated as part of Tabukan’s political territory, which had an established relationship with the VOC.
The Question Was Not Simply Who Found the Island First
In 1925, the United States and the Netherlands agreed to take the dispute to arbitration. Max Huber was appointed to determine which country held sovereignty over Palmas Island.
To make his decision, Huber had to answer one central question. Was Spain’s discovery of the island in the 16th century enough to give it sovereignty?
His answer was no.
Under international law at the time, discovering a territory was not enough to establish sovereignty. A country claiming a territory also had to show occupation or the actual exercise of authority over it.
In the case of Miangas, the United States could not show sufficient Spanish acts proving that Spain had exercised authority over the island. Even if Spain had gained an initial right through discovery, that right could not prevail over evidence that another power had exercised authority over the island continuously and peacefully.
This was where the evidence concerning Tabukan became important. The island had been treated as part of Tabukan’s territory since at least the early 18th century. For Huber, this carried more weight than simply having records showing that Spanish sailors had known the island existed.
From a Dutch Ruling to Indonesia
On April 4, 1928, Huber ruled that the entire island of Palmas belonged to the Netherlands. The decision established Miangas as part of the Dutch East Indies.
When Indonesia gained independence, the island subsequently became part of Indonesia. Today, Miangas is a district in the Talaud Islands Regency of North Sulawesi. It is also one of Indonesia’s outer small islands and serves as a baseline point for determining the country’s maritime boundaries.
So even though Miangas is closer to the Philippines, geography did not decide the dispute. What mattered was the evidence of which side could demonstrate an actual and sustained connection to authority over the island.
