Memorandum for the Petitioners| 6 estimated total of 1,023 GtCO2, or 66% of all anthropogenic CO2 from 1751 to 2016.'8 ‘ For the first time since climate change became a central issue for the public, consumers, and communities, there is evidence that the titans of fossil fuel industry are, in fact, overwhelmingly responsible for fueling climate change. The greenhouse gas (GHG) emissions linked to 50 of those investorowned producers, known collectively herein as respondent Carbon Majors, contribute to climate impacts in the Philippines, and in turn to human rights harms. Just 50 investor-owned companies contributed an estimated total 368 GtCOve (21.4%),.!? This is a landmark moment in history. Filipinos have strong grounds for demanding that respondents take immediate action to prevent the harm that they have so cavalierly disregarded at the expense of the people. Through this Honorable Commission’s valiance laws and standards, Filipinos have hope healthful ecology in accord with the highest attainable standard of physical in applying established human rights that their rights to life, a balanced and rhythm and harmony of nature, the and mental health, food, clean water, sanitation, adequate housing, development, self-determination, culture, and equality and non-discrimination, among others, will soon be vindicated. Only when the climate crisis is averted can Filipinos’ human dignity be restored. As espoused by Fr. Joaquin Bernas, one of the most respected constitutionalists in this jurisdiction, “with respect to the right to life, it is not just a protection of the right to be alive, or to the security of one’s limb against physical harm. The right to life is the right to a good life. The importance of the quality of living finds stronger emphasis in Article XIII, on social justice, and even the life of the unborn finds protection in the 1987 Constitution.”™ Consolidated Reply will be used by the petitioners when referring to the respondents for the purposes of this memorandum. '8 Exhibit “TTTT-A” to “TTTT-A-3,” Climate Accountability Institute, Press Release on Update of Carbon Majors Project, p. | (Updating Richard Heede’s 2013 study: see Exhibit “TTTT” to “TTTT-1,” Climate Accountability Institute, Press Release on Update of Carbon Majors Project; Exhibit “UUUU” to “UUUU103,” Carbon Majors: Accounting for Carbon and Methane Emissions 1854-2010 Methods and Results Report; and Exhibit “VVVV” to “VVVV- 14,” Tracing Anthropogenic Carbon Dioxide and Methane Emissions to Fossil Fuel and Cement Producers, 1854-2010). '9 Ibid. 29 Bernas, J.G. (2003), The 1987 Constitution of the Republic of the Philippines: A Commentary, 2003 ed.; Manila: Rex Book Store, p. 110.

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