98 advertisements acknowledge climate change, while 80 percent of advertisements expressed doubt.As documents become more publicly accessible, ExxonMobil increasingly communicated doubt, which reflected the Scientific Certainty Argumentation Method (SCAM), a tactic for undermining public understanding of scientific knowledge.464 From the foregoing, the Commission agrees that the Carbon Majors, directly by themselves or indirectly through others, singly and/or through concerted action, engaged in willful obfuscation of climate science, which has prejudiced the right of the public to make informed decisions about their products, concealing that their products posed significant harms to the environment and the climate system. All these have served to obfuscate scientific findings and delay meaningful environmental and climate action. An argument may be made under Philippine law that the acts of obfuscation, deception, and misinformation as described above contravene the standard of honesty and good faith expected of a person in the exercise of his rights. Articles 19 and 21 of the Civil Code of the Philippines465 provide: ARTICLE 19. Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith. xxx ARTICLE 21. Any person who willfully causes loss or injury to another in a manner that is contrary to morals, good customs or public policy shall compensate the latter for the damage. Other Possible Bases of Liability Aside from liability anchored on acts of obfuscation of climate science, fossil-based companies may also be held to account by their shareholders for continued investments on oil explorations for largely speculative purposes. Such reserves may, in the global march towards renewable energy, end up as stranded assets. Failure to comply with specific administrative or regulatory requirements, such as those in the nature of exacting transparency in business operations, may also be basis for establishing liability. 464 465 Exhibit J, Assessing ExxonMobil’s Climate Change Communications (1977-2014) dated 23 August 2017. An Act to Ordain and Institute the Civil Code of the Philippines [Civil Code], Republic Act No. 386 (1949) §§ 19 & 21.