Amicus Curiae Brief presented by ClientEarth 21 November 2016 20. This provision limits the judicial function to the Supreme Court and the lower courts established by law. In accordance with this clear constitutional separation of powers, the powers and functions of the Commission as expressed in Article 13 do not extend to the determination of legal rights and liabilities. The Commission has no power to determine actual controversies between individual private parties, between the Filipino state and its citizens, or between independent nation states. 21. The Commission’s investigatory and advisory function is clearly reflected by the Omnibus Rules of Procedure of the Commission on Human Rights (enacted under the power in section 18(2) of Article 8 of the Constitution) (Omnibus Rules). Section 2 of Rule 7 states that "[t]he investigative and inquiry proceedings of the CHR is factfinding in nature, and non-adversarial." 22. Furthermore, Rule 3 section 2, which describes the objectives of the Commission's investigation and monitoring function in respect of civil and political rights restricts the Commission's function to making findings of fact and recommendations to government. Section 17 of Rule 4 of the Omnibus Rules also makes it clear that the outcome of the Commission's investigation will be a final report containing those findings of fact, and corresponding recommendations as to appropriate criminal, administrative or civil actions to be taken by other organs of the state of the Philippines. These provisions confirm that the Commission is not empowered to exercise a judicial function under the Constitution of the Philippines. 3.2 Personal jurisdiction 12