Memorandum for the Petitioners \ 13
respective responses and reinforces petitioners’ arguments as to the propriety
of the Petition and the validity of their claims against respondents.
--
3.10. In May 2017, at least seven (7) respondent Carbon Majors
Chevron Corporation; Chevron Philippines, Inc. and Chevron Holdings, Inc.;
Chevron Geothermal Services Company, Chevron KalingaLtd ., and Chevron
Malampaya LLC; ConocoPhillips; Eni S .p.A; Repsol, S.A. and Repsol Oil
and Gas Canada Inc.; and The Shell Company of the Philippines, Limited and
Royal Dutch Shell filed their respective Rejoinders and/or letter response
to petitioners’ Consolidated Reply.
—
3.11. Beginning July 2017 up to November 2017, the Honorable
Commission conducted community visits and dialogues to select climateimpacted areas mentioned in the Petition and those which it deemed necessary
to visit due to climate impacts:
r
r
1.
2.
Libon, Albay;
Legazpi, Albay;
3. Tacloban City;
4. Tanauan , Leyte;
5. Province of Isabela;
6. Alabat Island;
7. Iligan City;
8. Bukidnon;
9. Cagayan de Oro City; and
10. Batangas City (Verde Island Passage).
3.12. On 11 December 2017, the parties held their first preliminary
conference wherein issues, list of witnesses, and initial pieces of evidence to
be presented were marked, discussed, and examined. Only petitioners were
present and none of the respondent Carbon Majors officially entered their
appearance for the preliminary conference, save for respondent Cemex
Mexico48 who made a special appearance and manifestation that they were not
participating in the proceedings. Meanwhile, the Honorable Commission
unequivocally denied all of the respondents’ motions to dismiss based on
jurisdictional grounds and asserted its authority to investigate the Petition and
hold public hearings for the whole year of 2018 in Manila, New York, and
London.49
3.13. On 19 March 2018, a group of the amicus submitters50 mentioned
above submitted a Joint Summary of the Amicus Curiae detailing the
following:
48
TSN dated 11 December 2017, p. 24.
Idpp. 4- 12.
50
CIEL (Erika Lennon, Carroll Muffett, Sebastien Duyck, Steven Feit & Lisa Hamilton); ClientEarth
(Sophie Marjanac); Environmental Law Alliance Worldwide (ELAW) (Killian Doherty & Jennifer
49