On March 14, 2018, Rodrigo Duterte, the Philippine President who is under preliminary examination by the ICC, announced that the country would withdraw from the Rome Statute. He argued that while the Statute was ratified by the Senate of the Philippines in 2011, it was never published in the Official Gazette of the Philippines, a requirement for penal laws (of which the Rome Statute subscribes as such) to take effect. Hence, he claimed that the Philippines was never a State Party "ab initio". Additionally, he stated that the ICC was being utilized as a political tool against weak targets such as the Philippines. The United Nations received the official notification of withdrawal on March 17, 2018; one year later (March 17, 2019), by rule, the Philippines' withdrawal became official. The legal validity of the withdrawal was challenged at the Supreme Court of the Philippines, was dismissed in a unanimous decision for being "moot and academic" 2 years after the country's official withdrawal from the tribunal.