27 following. . . .” are indicative of this non-restrictive and non-exhaustive inventory of human rights involving civil and political rights. 2.56. In fact, as shown, the framers of the Constitution hesitated to define and enumerate human rights involving civil and political rights, acknowledging that the term is broad and evolving. i. The Honorable Commission has the authority to investigate “environmental rights,” which are assumed to exist from the inception of humankind and inextricably linked to the general concept of human rights. 2.57. The Supreme Court’s pronouncements in Oposa, et al. v. Factoran, Jr. et al.98 were strongly echoed in the most recent cases of: (a) Henares, Jr., et al. v. Land Transportation Franchising and Regulatory Board, et al.99; (b) Metropolitan Manila Development Authority, et al. v. Concerned Residents of Manila Bay, et al.100; and (c) the consolidated cases of Resident Marine Mammals of the Protected Seascape Tañon Strait, et al. v. Secretary Angelo Reyes, et al.101 and Central Visayas Fisherfolk Development Center (FIDEC), et al. v. Secretary Angelo Reyes.102 2.58. In the Rationale to the Rules of Procedure for Environmental Cases (Administrative Matter [A.M.] No. 09-6-8-SC),103 the Supreme Court acknowledged that, “[a] growing number of international instruments as well as national constitutions, domestic legislations and academic literature have recognized the inextricable link between human rights and environmental rights.”104 The Supreme Court added that, “[i]t is significant to note that a fair amount of literature on the origins of environmental rights documents in parallel that the ‘right to an adequate environment’ or what is collectively known as ‘environmental rights’ grew out of a human rights framework.”105 2.59. The propriety of this Petition is also supported by the recognition of the human rights implications of climate change by the UN Human Rights Council, Special Procedures of the UN Human Rights 98 Oposa, et al. v. Factoran, Jr. et al., G.R. No. 101083, 30 July 1993. G.R. No. 158290, 23 October 2006. 100 G.R. Nos. 171947-48, 18 December 2008. 101 G.R. No. 180771, 21 April 2015. 102 G.R. No. 181527, 21 April 2015. 103 Available at http://philja.judiciary.gov.ph/assets/files/pdf/learning_materials/A.m.No.09-6-8SC_rationale.pdf, last accessed on 01 January 2017 104 Citations omitted; Emphasis supplied; Rationale to the Rules of Procedure for Environmental Cases, op cit., p. 50. 105 Rationale to the Rules of Procedure for Environmental Cases, p. 50, available at http://philja.judiciary.gov.ph/assets/files/pdf/learning_materials/A.m.No.09-6-8-SC_rationale.pdf, last accessed on 01 January 2017 (Emphasis supplied). 99