43 the survivors of extreme weather events are again victimized by the violation of their rights to water and sanitation. v. Right to Livelihood Article 6 of the ICESCR recognizes “the right to work, which includes the right of everyone to the opportunity to gain his living by work which he freely chooses or accepts.”202 Meanwhile, Article II, Section 9 of the Philippine Constitution provides that the State shall “promote full employment, a rising standard of living, and an improved quality of life for all,”203 and Sections 3 and 9 of Article XIII thereof recognize and promote the importance of equal employment opportunities for all. However, the IPCC notes that climate change affects both access to and the quality of natural resources that sustain livelihoods.204 In the agricultural sector, farmers experience a higher incidence of pests and diseases, low crop productivity/ yield, stunted growth, delays in fruiting and harvesting, declining quality of produce, increased labor costs, and low farm income.205 Increased rainfall has also caused prolonged inundation and destruction of crop fields–particularly rice, which is especially vulnerable to water stress.206 The weather unpredictability has “made rice-planting less exact and more like guesswork.”207 Yields of other crops were also drastically reduced, making farming less viable as a source of livelihood, and forcing communities to shift to other industries such as construction work. 208 Buucan Hangdan, an indigenous farmer of the Ifugao tribe residing in the Banaue Rice Terraces, described the disruption in this manner: 202 ICESCR, supra note 153, art. 6, para. 1. 203 Phil. Const. art. II, § 9. 204 IPCC, AR5 WGII, supra note 159, at 1068. 206 L. M. Peñalba, D. D. Elazegui, M. G. C. Amit, F. P. Lansigan, & F. J. G. Faderogao, Meeting the Challenges to Food Security and Livelihood in a Changing Climate (Center for Strategic Planning and Policy Studies Working Paper No. 2012-01, 2012). 205 Lutgarda L. Tolentino & Leila D. Landicho (2013). Climate Change Adaptation Strategies of Selected Smallholder Upland Farmers in Southeast Asia: Philippines And Indonesia, 3 APN Sci. Bull. 61 (2013). 207 Ma. Lourdes P. Kempis, 15 December 2017, Leyte Community Dialogue, at 9. 208 Id.