especially with respect to the conditions of those who are marginalized, disadvantaged, and vulnerable. Rule 3(2): To determine whether civil and political rights have been violated, are being violated ... by … private person or entity. The objectives of investigation and monitoring of economic, social and cultural rights violations or situations are: to determine the rights violated by State or non-state actors, including private entities and individuals …. 3 The following additional arguments are presented by ClientEarth: -- As the Commission’s constitutional mandate expressly includes investigating matters affecting the human rights of Filipinos abroad, its investigative function should not be read to only include matters affecting human rights violations or threats of violations that originate inside the Philippines.4 The Philippines has acknowledged that climate change will affect civil and political rights in the Philippines,5 and the Omnibus Rules of Procedure provide the Commission with the power to address “threats of violations,” including those arising from the expected impacts of climate change.6 -- The separation of powers in the Philippines Constitution prevents the Commission from exercising judicial power.7 Article 13(18) clearly limits the Commission’s powers to administrative functions including investigating and monitoring human rights and making recommendations (inter alia).8 The Commission’s constitutionally limited role is reflected in the Omnibus Rules of Procedure of the Commission. 9 The Commission’s power to conduct the investigation is therefore not limited by rules governing the exercise of judicial power such as the principle of territoriality.10 -- It should be noted that the Petition does not ask the Commission to exceed the bounds of its constitutional mandate, and requests that it only make factual findings and issue recommendations to the Congress of the Philippines. 11 In addition, APF and GANHRI note in their brief that some respondents have asserted that the Omnibus Rules explicitly extending the Commission’s jurisdiction to investigate 3 COMM’N ON HUMAN RIGHTS OF THE PHILIPPINES, GUIDELINES AND PROCEDURES IN THE INVESTIGATION AND MONITORING OF HUMAN RIGHTS VIOLATIONS AND ABUSES, AND THE PROVISION OF CHR ASSISTANCE, Rule 2, § 12, Rule 3, § 2-3, i-ii, iv-v, available at https://pinoyfilecabinet.files.wordpress.com/2014/07/chr-proceduresfinal_approved_8-31-2012.pdf (emphasis added) [hereinafter Omnibus Rules]. 4 Amicus Curiae Brief submitted by ClientEarth, ¶¶ 23-24, https://businesshumanrights.org/sites/default/files/documents/ClientEarth.pdf [hereinafter ClientEarth brief]. 5 Id. at ¶¶ 33-34. 6 Id. at ¶¶ 35-36. 7 Id. at ¶¶ 19-20. 8 Id. at ¶¶ 17-18. 9 Id. at ¶¶ 20-21. 10 Id. at ¶ 23. 11 Id. at ¶¶ 38-39. 12