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Personally I wouldn't consider it a legendary. However;

Phione's mythical and/or legendary status has been heavily disputed due to the fact it is easy to obtain lots of Phione on the same game card without cheating should one have a Manaphy or a Phione and a Ditto, even official sources have differed on the matter.

However like I said, from my point of view it isn't a legendary. While it may being the offspring of a legendary and part of the Sea Guardians, it's stats are subpart for a legendary, and I really don't see what it represent's that Manaphy doesn't already. Additionally it's too easy to get to really amount to being a legendary which are generally considered rare.

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Here are some things the other answer doesn't mention.

Phione's status as a Mythical Pokémon is disputed, with several pieces of evidence and even official statements often contradicting each other.

Evidence for:

  • Phione is listed under the Mythical Pokémon section in the Pokémon 2011 Style Guide.
  • Phione is listed as a Mythical Pokémon in the Pokémon Deluxe Essential Handbook.
  • Phione was a usable Pokémon in the Circle of Legends tournament, in which only Legendary and Mythical Pokémon were allowed.
  • Phione is banned from the 2016 Video Game Championships due to being a Mythical Pokémon.
  • Phione is listed as a Mythical Pokémon in a September 2016 Nintendo feature story on Mythical Pokémon.
  • Phione is not found in any regional Pokédex, a trait that is otherwise exclusive to Generation IV Legendary and Mythical Pokémon.
  • Phione is also not needed to obtain the diploma, a trait otherwise exclusive to Mythical Pokémon.
  • Phione is banned from the Battle Frontier, the Battle Subway, the Pokémon World Tournament, and the Battle Maison, a rule which typically applies only to Mythical Pokémon and major Legendary Pokémon; the only non-Mythical Pokémon to have been event-only at one point, Zorua and Zoroark, were allowed in the Battle Subway, indicating Phione's battle facility ban may be due to it being Mythical.
  • Phione is also banned from most online competitions and online battles.
  • In Explorers of Time, Darkness and Sky, Phione has a 100% recruit rate, is never battled, and the player is not allowed to recruit more than one to their team, all of which are traits otherwise only exhibited by Legendary and Mythical Pokémon.
  • In Super Mystery Dungeon, Hoopa is able to summon Phione as an ally. Only Legendary and Mythical Pokémon are able to be summoned in this way.
  • In Pokémon Rumble Blast, Phione can only be unlocked once a certain number of customers have shopped at the Toy Shop, a trait otherwise exclusive to Legendary and Mythical Pokémon.
  • Phione was featured in Pokémon.com's 2012 Pokémon Power Bracket, a single-elimination tournament where all other Pokémon in the bracket were Legendary and Mythical Pokémon.

Evidence against:

  • Phione can breed to produce another Phione; this is impossible with any other Legendary and Mythical Pokémon. However, Manaphy can also breed to produce Phione, and Manaphy is a confirmed Mythical Pokémon.
  • Pokémon HeartGold and SoulSilver: Prima's Official Strategy Guide states that Phione is not Legendary (a term used at the time to describe both Legendary and Mythical Pokémon) due to it being able to be obtained by hatching Eggs.
  • In Pokémon Ranger: Guardian Signs, all Mythical Pokémon are referred to as "rare," but Phione is not. It is also found normally in the wild.

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