TABLE OF CONTENTS
(Memorandum of the Petitioners dated 18 September 2019)
I.
Prefatory Statement
2
II.
The Case
7
III.
The Proceedings
9
IV.
The Honorable Commission’s Authority to Investigate
and Grant the Reliefs prayed for by the Petitioners
20
V.
Material Facts as Established by Evidence
25
A. Basic climate science and understanding climate change
in a global context
B. IPCC reports as material facts
C. Impacts felt and projected can be attributable to specific
human activities
D. Respondent Carbon Majors’ knowledge of climate risks and
actions and/or inactions in light of foreseeable climate harms
25
Brief Statement of Petitioners’ Position
67
A. Climate science
B. The human rights harms being suffered by the petitioners
and the Filipinos
C. Respondent Carbon Majors’ knowledge of foreseeable climate
risks and harms to people
D. Respondent Carbon Majors’ responsibility to respect and
protect human rights under international law and agreements
E. Respondents’ moral and legal responsibility under general
principles of tort and human rights law
67
68
VI.
VII. Issues
27
38
41
68
70
71
72
A. Whether climate change is impacting the Philippines
B. Whether climate change results in – and/or threatens -- the
impairment, infringement, abuse, and/or violation of the human
rights of Filipinos
C. Whether respondent Carbon Majors significantly contribute
to climate change
D. Whether respondent Carbon Majors’ actions and/or inactions
are linked to the climate change impacts occurring and/or
threatening to occur in the Philippines
E. Whether respondent Carbon Majors are responsible, under
international laws and agreements and domestic laws to respect
and protect the human rights of Filipinos in the context of climate