37 of the state and not of corporations;152 and if, indeed, one of the objectives of the Petition is for the Honorable Commission’s exercise of monitoring power. In similar evasive tone, respondent LafargeHolcim argued that the petitioners must seek remedies from their national government, and not from the transnational corporations.153 The objective of this Petition is precisely to activate a potential process whereby the Honorable Commission can help in the realization of the State of the Philippines’ obligations to protect human rights of those within its jurisdiction from harmful corporate conduct. D. Refutations to other “jurisdictional” matters raised by the respondents. D.1. The petitioners are invoking this Honorable Commission’s investigatory, recommendatory, and monitoring powers, as expressly conferred by the Constitution, and not its quasi-judicial function. 2.88. To emphasize, petitioners are invoking this Honorable Commission’s investigatory, recommendatory, and monitoring powers as expressly conferred by the Constitution— “(1) Investigate, on its own or on complaint by any party, all forms of human rights violations involving civil and political rights; xxx (6) Recommend to the Congress effective measures to promote human rights and to provide for compensation to victims of violations of human rights, or their families; (7) Monitor the Philippine Government’s compliance with international treaty obligations on human rights; xxx.”154 2.89. Contrary to the reasoning of respondents Cemex,155 ExxonMobil,156 and LafargeHolcim,157 petitioners are not seeking this Honorable Commission’s quasi-judicial power. The procedure upon which this national public inquiry would be carried out, according to the Honorable 152 Respondent ExxonMobil’s Motion to Dismiss Ad Cautelam dated 13 September 2016, para. 18. Respondent LafargeHolcim’s Manifestation Ad Cautelam (Without Any Acceptance or Submission to Jurisdiction) dated 15 September 2016 with attached letter from LafargeHolcim dated 13 September 2015, Letter C, p. 5 of the attached letter. 154 Section 18, Article XIII of the 1987 Philippine Constitution. 155 See Cemex’s Entry of Special Appearance with Motion to Dismiss dated 14 September 2016, Letter C, p. 2 thereof. 156 See ExxonMobil’s Motion to Dismiss Ad Cautelam dated 13 September 2016, Nos. 31-32, pp. 9-10 thereof. 157 See LafargeHolcim’s Manifestation Ad Cautelam (Without Any Acceptance or Submission to Jurisdiction) dated 15 September 2016 with attached letter from LafargeHolcim dated 13 September 2015, Letter C, p. 5 of the attached letter. 153

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