Until the 1990s when Democratic Progressive Party (DPP) joined Kuomintang (KMT) to amend the constitution, the document was considered illegitimate by pro-independence advocates because it was not drafted in Taiwan; moreover, they deemed Taiwan to be sovereign Japanese territory until ceded in the San Francisco Peace Treaty effective April 28, 1952. Pro-independence advocates have argued that the Constitution was never legally applied to Taiwan because Taiwan was not formally incorporated into the ROC's territory through the National Assembly as per the specifications of Article 4. Though the constitution promulgated in 1946 did not define the territory of the Republic of China, while the draft of the constitution of 1925 individually listed the provinces of the Republic of China and Taiwan was not among them, since Taiwan was part of Japan as the result of the Treaty of Shimonoseki of 1895. The constitution also stipulated in the Article I.4, that "the territory of the ROC is the original territory governed by it, unless authorized by the National Assembly, can not be altered." In 1946, Sun Fo, the minister of the Executive Yuan of ROC reported to the National Assembly that "there are two types of territory changes: 1. renouncing territory and 2. annexing new territory. The first example would be the Independence of Mongolia, and the second example would be the reclamation of Taiwan. Both would be examples of territory changes. No such formal annexation of Taiwan islands by the ROC National Assembly conforming with the ROC constitution ever occurred since 1946, even though Article 9 of the says, "The modifications of the functions, operations, and organization of the Taiwan Provincial Government may be specified by law." The Republic of China argues that sovereignty of the Republic of China over Taiwan was established by the Instrument of Surrender of Japan which implemented the Potsdam Declaration and the Cairo Declaration. The Allies have not agreed or disagreed to this rationale. In addition, the ROC argues that the Article 4 of Treaty of Taipei nullifies the Treaty of Shimonoseki and the original transfer of sovereignty of Taiwan from China to Japan. Since this transfer of sovereignty occurred in 1945 before the promulgation of the 1947 constitution, the ROC government is of the view that a resolution by the National Assembly was unnecessary.