44 investigation, and are not seeking to recover money or obtain possession of property. Therefore, the automatic stay is not applicable to the instant proceeding. E. The Petition sets out ample scientific and legal grounds for the Honorable Commission’s investigation. 2.108. Respondents ExxonMobil and LafargeHolcim further argue that the Petition should be dismissed because, allegedly, it fails to state a cause of action against the respondents.172 At the outset, it is essential to recall the aim of the Petition: To request the Honorable Commission to “conduct an investigation into the human rights implications of climate change and ocean acidification and the resulting rights impacts in the Philippines.”173 2.109. According to Section 2, Rule 7 of the Omnibus Rules of the Commission, “the investigative and inquiry procedure of the [Commission] is fact-finding in nature, and non-adversarial.”174 This differs from a civil action where a complaint must set out specific claims.175 The respondents’ argument is not relevant to this inquiry procedure, which must be allowed to investigate the issue of responsibility first and foremost. The Petition, however, sets out ample scientific and legal grounds for the Commission’s investigation. 2.110. First, respondent Carbon Majors have contributed 337.7 Gt CO2e, equivalent to 21.6% of estimated global industrial emissions through 2013, fuelling the climate change impacts being experienced today and well into the future.176 2.111. Second, the adverse impacts of climate change and ocean acidification have harmed or threaten to harm people and communities, on top of, or in addition to, damage resulting from natural disasters. These 172 Respondent ExxonMobil’s Motion to Dismiss Ad Cautelam dated 13 September 2016, p. 13; 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. 6 of the attached letter. 173 Petition dated 09 May 2016, p. 61, available at http://www.greenpeace.org/seasia/ph/PageFiles/735232/Climate_Change_and_Human_Rights_Petition.pdf 174 Section 2, Rule 7, Omnibus Rules of the Commission. 175 A complaint states a cause of action if it sufficiently avers the existence of the three (3) essential elements of a cause of action, namely: (a) a right in favor of the plaintiff by whatever means and under whatever law it arises or is created; (b) an obligation on the part of the named defendant to respect or not to violate such right; and (c) an act or omission on the part of the named defendant violative of the right of the plaintiff or constituting a breach of the obligation of defendant to the plaintiff for which the latter may maintain an action for recovery of damages. See Zuniga-Santos v. Santos-Gran, et al., G.R. No. 197380, 08 October 2014. 176 See Annex “F” to the Petition, available at http://www.greenpeace.org/seasia/ph/press/releases/Worldslargest-carbon-producers-ordered-to-respond-to-allegations-of-human-rights--abuses-from-climatechange/The-Climate-Change-and-Human-Rights-Petition/, last accessed on 08 February 2017.