sustaining life.”25 The Court also ruled that “every generation has a responsibility to the next to preserve that rhythm and harmony for the full enjoyment of a balanced and healthful ecology.” 26 The public trust obligation of the Philippine government was reinforced by the Metro Manila case in 2008, in which the Philippine Supreme Court ruled the government had an obligation to clean up Manila Bay. Even assuming the absence of a categorical legal provision specifically prodding petitioners to clean up the bay, [the government agencies] cannot escape their obligation to future generations of Filipinos to keep the waters of the Manila Bay clean and clear as humanly as possible. Anything less would be a betrayal of the trust reposed in them.27 It is important to note that the Philippine government not only has the obligation to protect Filipinos’ “right to a balanced and healthful ecology,” but it also has the authority to do so because it is the owner of “all lands of the public domain, waters, minerals, coal, petroleum, and other mineral oils, all forces of potential energy, fisheries, forests or timber, wildlife, flora and fauna, and other natural resources…” and is entrusted to care for these sovereign assets. 28 Analyzing the Court’s ruling in the Metro Manila case and previous jurisprudence interpreting the public trust obligation of the Philippine government, public trust scholar and Law Professor Michael Blumm notes that “the purposes of the public trust doctrine in the Philippines extend not only to the management and conservation of natural resources, but also to their equitable distribution among generations.” 29 The Philippines is not alone in this interpretation of the scope of the public trust and constitutional rights protecting the interests of future generations. 30 In November 2016, U.S. 25 Oposa v. Factoran, G.R. No. 101083, 224 SCRA 792 (S.C., July 30, 1993) (Phil.). Id. 27 Metro. Manila Dev. Auth. v. Concerned Residents of Manila Bay (Metro Manila), G.R. No. 171947-48, 574 S.C.R.A. 661 (S.C., Dec. 18, 2008) (Phil.) available at http://sc.judiciary.gov.ph/jurisprudence/2008/december2008/171947-48.htm. 28 Petition for Writ of Kalikasan and Writ of Continuing Mandamus in re: Segovia, et. al. v. The Climate Change Commission, et. al., 23 (2014) https://www.ourchildrenstrust.org/s/Philippines-Petition.pdf; see also Article XII, Sec. 2 of the 1987 Constitution. 29 Michael C. Blumm & Rachel D. Guthrie, Internationalizing the Public Trust Doctrine: Natural Law and Constitutional and Statutory Approaches to Fulfilling the Saxion Vision, 45 U.C. Davis L. Rev. 741, 775 (2012) [hereinafter Internationalizing the Public Trust Doctrine]. 30 The fundamental obligation of sovereign States to protect and maintain crucial natural resources on behalf of current and future generations arises out of the public trust doctrine. The fiduciary duty of the Sovereign trustees and the rights conferred to the beneficiary present and future generations under the doctrine predate and exist independent of modern articulation and codification of the doctrine. See, e.g., Gerald Torres & Nathan Bellinger, The Public Trust: The Law’s DNA 4 Wake Forest J.L. & Pol’y 281, 288 (2014) [hereinafter Public Trust: Law’s DNA] (“The public trust doctrine is “inherent to humankind and merely secured by government.”); Blumm & Guthrie, Internationalizing the Public Trust Doctrine, at 750 (stating that the doctrine is approaching becoming a “general principle of international law”); Mary Christina Wood, Atmospheric Trust Litigation Across the World, in Fiduciary Duty and the Atmospheric Trust (Ken Coghill et al. eds., 2012) [hereinafter Atmospheric Trust Litigation]. This obligation is articulated in various international treaties from those directly requiring action on climate change, such as the Paris Agreement, to those that address the range of human rights impacted as a result of climate change, such as the Convention on the Rights of the Child and the International Covenant on Economic, Social and Cultural Rights. Finally, the obligations and rights under the public trust doctrine exist within the fabric of Constitutions and other domestic laws of nations, implicitly and, at times, explicitly. Torres & Bellinger, Public Trust: Law’s DNA, at 26 Our Children’s Trust Amicus Curiae Brief 6