Pagta as we have discussed is a form of contract between two minds, the terms of which were not reduced into writing until the Pagta of the Kalingas were codified by its local government.

Like all contracts, pagtas do have solemnities, which the parties must observe with utmost good faith.

There must be good faith for its absence would undermine the purpose for which a contract was entered into by and between the parties thereto.

For civil contracts, there are formalities that must be followed before the same may be valid and enforceable in the courts of law in the Philippines. Under the Statutes of Frauds, there are certain contracts, like sale of a land or the transfer of right over it, that the contract must be in WRTING, in order that it mat be enforceable. And under certain provision of the Civil Code, the the contract must be in a public instrument in order that the same may be valid.

As for pagtas, it is sufficient that the parties thereto agreed upon the terms and conditions of the contract. An agreement may be defined as the meeting of the minds of the parties in a contract. There is no requirement that the same must be in writing in order for it to be enforceable according to the laws and customs of the place.

In fine, a pagta may or may not be in writing. As for the Kalingas, the original pagtas were done orally - but the same continued to govern the parties in the pagta.