investigate the Petition. In this connection, it is irrelevant whether any of the major emitters do business in the Philippines, as long as the effects of their activities may be regarded as a threat to essential or vital interests of the Philippines. APF and GANHRI note that in any event, it is not up to the respondents to protest against breaches of sovereignty and abuses of jurisdiction; such protests are the sole prerogative of States.48 In the Lotus case, the Permanent Court of International Justice specifically considered whether the burden of proof lies with the State that claims it is entitled to exercise legislative and adjudicative jurisdiction, or whether it lies with the State claiming that such jurisdiction is illegal, and opined that it fell on the latter. 49 There is, moreover, no assumption in international law that individuals or corporations will be regulated only once, and situations of multiple jurisdictional competence occur frequently. In such situations there is no “natural” regulator and the consequences of multiple laws applying to the same transactions are managed, rather than avoided.50 V. The broad scope of the Commission’s mandate is reinforced by the Principles relating to the Status of National Institutions The Principles relating to the Status of National Institutions, known as the Paris Principles, adopted by the UN General Assembly in 1993, state that National Human Rights Institutions (NHRIs) “shall be given as broad a mandate as possible.” 51 The Sub-Committee on Accreditation’s General Observations, which aim to guide the interpretation and implementation of the Paris Principles, further instruct: A National Institution’s mandate should be interpreted in a broad, liberal and purposive manner to promote a progressive definition of human rights which includes all rights set out in international, regional and domestic instruments, including economic, social and cultural rights. Specifically, the mandate should: extend to the acts and omissions of both the public and private sectors; . . . provide the authority to address recommendations to public authorities, to analyse the human rights situation in the country, and to obtain statements or documents in order to assess situations raising human rights issues. 52 VI. Human rights law practice Plan B’s brief asserts that it is the responsibility of governments to take measures to protect the fundamental rights of their citizens, regardless of the source of threat. 53 For example, Article 1 of the European Convention on Human Rights states: “The High Contracting Parties shall secure to everyone within their jurisdiction the rights and freedoms defined in Section I of this Convention (…)” (emphasis added). 48 See APF & GANHRI brief, at ¶ 15 (and sources cited therein). S.S. Lotus Case, 1927 P.C.I.J. (ser. A) No. 10, at 19-20. 50 MALCOLM EVANS, ED., INTERNATIONAL LAW, 457 (4th ed. 2014). 51 G.A. Res. 134, U.N. Doc. A/RES/48/134, Principle 2 (Dec. 20, 1993); see ELAW brief, at pgs. 13-14. 52 INT’L COORDINATING COMM. OF NAT’L INST. FOR THE PROMOTION AND PROTECTION OF HUMAN RIGHTS, ICC SUB-COMMITTEE ON ACCREDITATION GENERAL OBSERVATIONS AS ADOPTED IN MAY 2013, G.O. 1.2, 13 (2013). 53 See Plan B brief, at § 2.2 (p. 5). 49 18

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