MANILA (UPDATE) - Filipinos should be "very wary" of what's happening at the Julian Felipe Reef, where around 183 Chinese vessels were moored, as it may be a prelude to occupation and building of a naval base, retired Supreme Court Senior Associate Justice Antonio Carpio said Wednesday.

Carpio, who was among legal luminaries that represented Manila before an international tribunal in its case against Beijing, said China cannot park its militia vessels at the Julian Felipe Reef "because that is not their exclusive economic zone." There were also no storms around the area as was previously claimed.

He added, this was not the first time this happened because at the same time last year, there were also "hundreds" of Chinese ships parked at the reef.

"The way I look at it, this is a prelude to occupying the Julian Felipe Reef, just like what they did to Mischief Reef in 1995. They started with saying they just built fishermen shelter on Mischief Reef. Now, Mischief Reef is their air and naval base, they call it their Pearl Harbor in the South China Sea. It’s a huge air and naval base," Carpio told ANC's Headstart.

"I’m particularly worried that they will now start claiming, building on Julian Felipe Reef just like what they did on Mischief Reef," he added.

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Authorities said the Philippine Coast Guard had reported that about 220 vessels, believed to be manned by Chinese maritime militia personnel, were sighted in line formation at the Julian Felipe Reef on March 7.

Armed Forces of the Philippines Chief of Staff Gen. Cirilito Sobejana said 183 vessels were still seen on Monday morning in the area that China calls Niu'e Jiao and claims to be part of its Nansha Undao.

The Philippines has since filed a diplomatic protest over their presence at the reef, which is located approximately 175 nautical miles west of Bataraza, Palawan.

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Carpio said while it's not immediately clear when exactly China will build on Julian Felipe Reef, "that has been their playbook, that’s what they did to Mischief Reef, Subi Reef, and even in Sandy Cay."

"We should be wary, very wary of what’s happening in Julian Felipe Reef," he said.

As this reef is within the Philippines' exclusive economic zone, Carpio said the resources there are reserved for Filipino citizens and under the Constitution, "the government is mandated to protect our marine wealth in Julian Felipe Reef."

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As the Palace indicated that President Rodrigo Duterte would meet with Chinese Ambassador Huang Xilian, Carpio said the chief executive should tell China to back off from the West Philippine Sea if Beijing is truly Manila's friend.

"The President should say that friends do not seize, do not occupy the backyard of each other. If the Chinese are friends, it should not seize our territorial maritime zones," he said.

"If there’s a dispute with us, settle it through third party arbitration. They should not unilaterally just seize our territory and maritime zones in the South China Sea. Friends do not do this to each other," he added.

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China's sweeping claims in the South China Sea, which the West Philippine Sea is a part of, has been invalidated by an international arbitral tribunal in 2016.