28 Council, the nations participating in the Climate Vulnerable Forum, and the Government of the Philippines.106 2.60. As a matter of fact, in issuing the Rules of Procedure for Environmental Cases,107 the Supreme Court noted that “[t]he protection of environmental rights in a human rights context at a domestic level is not a new concept. Many countries around the world provide some protection of environmental rights within their human rights charters.”108 The Supreme Court cited Earthjustice’s 2005 Environmental Rights Report (Human Rights and the Environment), to wit: “Numerous constitutions of the nations of the world guarantee a right to a clean and healthy environment or a related right. Of the approximately 193 countries of the world, there are now 117 whose national constitutions mention the protection of the environment or natural resources. One hundred and nine of them recognize the right to a clean and healthy environment and/or the state’s obligation to prevent environmental harm. Of these, 56 constitutions explicitly recognize the right to a clean and healthy environment, and 97 constitutions make it the duty of the national government to prevent harm to the environment. Fifty-six constitutions recognize a responsibility of citizens or residents to protect the environment, while 14 prohibit the use of property in a manner that harms the environment or encourage land use planning to prevent such harm. Twenty constitutions explicitly make those who harm the environment liable for compensation and/or remediation of the harm, or establish a right to compensation for those suffering environmental injury. Sixteen constitutions provide an explicit right to information concerning the health of the environment or activities that may affect the environment.”109 2.61. The inextricable relationship of environmental and human rights calls for a holistic and integrated approach in the treatment of issues, contrary to the view of the respondents. ii. 106 The Honorable Commission is duty-bound to protect and promote all forms of human rights found in international human rights and environmental agreements. Please see discussion on this point in the Petition dated 09 May 2016, pp. 8-15. A.M. No. 09-6-8-SC 108 Rationale to the Rules of Procedure for Environmental Cases, supra. 109 Earthjustice’s 2005 Environmental Rights Report (Human Rights and the Environment), available at http://earthjustice.org/sites/default/files/library/references/2005_ENVIRONMENTAL_RIGHTS_REPORT rev.pdf, last accessed on 01 January 2017. 107

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