Memorandum for the Petitioners [ 73 OF FILIPINOS IN THE CONTEXT OF CLIMATE CHANGE. VIII ARGUMENTS AND DISCUSSION A IS CHANGE CLIMATE IMPACTING THE PHILIPPINES SUFFER FILIPINOS AND DISPROPORTIONATELY FROM THESE IMPACTS. r r 8.1. The Philippines is highly vulnerable to the impacts of climate change: indeed , in the World Index Report 2016,302 the Philippines ranked number three in terms of exposure and vulnerability. This was attributed to the number of tropical cyclones and also the number of disasters that are being experienced in the country, 303 In the most recent Global Peace Index , published by the Australian think-tank Institute for Economics and Peace (IEP), the Philippines climbed the ladder and ranked Number 1 in terms of exposure to climate hazards.304 8.2. As testified to by expert witness Ms. Rosalina De Guzman, Assistant Weather Services Chief of the Philippine Atmospheric, Geophysical and Astronomical Services Administration (PAGASA ), since the 1950s, the Philippine climate, like the rest of the world, is warming. From 1951-2010, the annual mean temperature has increased by 0.65°C.305 Daily temperature extremes show more hot days and fewer cold nights.306 United Nations University Institute for Environment and Human Security, World Risk Report 2016, available at https://collections.unu .edU/eserv/UNU:5763/WorldRiskReport2016_small meta.pdf (last accessed on 06 September 2019); Also see: Testimony of Ms. Rosalina De Guzman, TSN 27-28 March 2018, available at http://chr.gov.ph/wp-content/uploads/2019/04/NICC-TSN-March-27-to-28-2018-MetroManila- Philippines.pdf (last accessed on 12 September 2019). 303 De Guzman, R., TSN 27-28 March 2018, p. 92, supra note 302. 304 Institute for Economic and Peace, Global Peace Index 2019, Figure 2.35, p. 48, available at https://reliefweb. int/sites/reliefweb.int/files/resources/GPI-2019-web003 . pdf ( last accessed on 12 September 2019). 305 See Exhibit “W” to “ W- 14,” Cinco, TA., et al. (2014), Long-term trends and extremes in observed daily precipitation and near surface air temperatures in the Philippines for the period 1951-2010, Atmospheric Research Vol . 145- 146, Fig 2, p. I 7, also available at https://www.sciencedirect.com /science/article/ pii /S 0169809514001495 (last accessed on 12 September 2019). 306 This observation was based on the trends in the frequency of days with minimum temperature below the th 1st percentile (cold nights) and the trends in frequency of days with maximum temperature above the 99 percentile ( hot days); See: Exhibit “ V” to “V-2,” Statement of Ms. Rosalina de Guzman, dated 16 March 2018, p. 1 . 302