a framework in which right holders can realise their rights against abuses by third parties.21 The ECOWAS Community Court found the duty to protect in its decision in the 2012 case SERAP v. Federal Republic of Nigeria. Nigeria had a duty to protect the human rights of its most vulnerable rights holders that were affected by oil companies’ abuses.22 The ECtHR found a similar duty to protect against human rights abuses in its decision in Kalender v. Turkey. In this case, Turkey had not put in place the appropriate safety measures and also had failed to investigate a corporation for potential liability in causing the death of an individual in connection to the lack of safety standards.23 The duty to protect human rights has been repeated in the jurisprudence of numerous judicial and quasi-judicial authorities and should inform this Commission that the Philippines has this same duty to protect against human rights abuses within its own jurisdiction. Article 11(1) of the ICESCR articulates a State’s duties in regards to protecting an adequate standard of living for its people. Article 11(1) provides that, “[t]he States Parties to the present Covenant recognize the right of everyone to an adequate standard of living for himself and his family, including adequate food, clothing and housing, and to the continuous improvement of living conditions. The States Parties will take appropriate steps to ensure the realization of this right, recognizing to this effect the essential importance of international co-operation based on free consent”24 (emphasis added). The language in Article 11(1) particularizes for the rights to food, clothing, housing, among others, the general obligation found in the abovereferenced Article 2(1) of the ICESCR. In the present case, the petition alleges that the Carbon Majors’ business activities have substantially impaired the people of the Philippines’ right to an adequate standard of living. 25 The Philippines therefore has a duty to assess the impact of the mentioned business activities on human rights including on the rights to water, housing, food, sanitation, health and other rights, and may exercise that duty through a variety of means, including the work of the Commission. The Philippines is also a State Party to the Convention on the Rights of the Child (CRC) and as such, has an obligation to safeguard the rights of children under its jurisdiction.26 The Committee on the Rights of the Child has elaborated in some 21 Id. 22 SERAP v. Federal Republic of Nigeria, The Court of Justice of the Economic Community of West African States (ECOWAS), Judgment of 14 December 2012, N° ECW/CCJ/JUD/18/12. 23 Kalender v. Turkey, No.4314/02, 15 December 2009, ECHR 2009. 24 UN General Assembly, International Covenant on Economic, Social and Cultural Rights, 16 December 1966, United Nations, Treaty Series, vol. 993. 25 See Petition “Statement of Facts,” at 21 – 29 for specific examples. 26 UN General Assembly, Convention on the Rights of the Child, 20 November 1989, United Nations, Treaty Series, vol. 6