Memorandum for the Petitioners |105
Bahian, “ Ms. Piquero-Tan, “? Ms. Ubaldo, “84 Ms. Cocadiz,‘®5 and Ms.
Bacason** -- who testified and shared their heartbreaking ordeals on either
relocating almost every time typhoon hits their place, having to live in tents
for months, or migrating abroad for safety.
8.95. Without adaptation, the IPCC projects with high confidence that
“hundreds of millions of people will be affected by coastal flooding and will
be displaced due to land loss by year 2100.48” Drought and desertification
could lead to the displacement of millions more people.‘*8
8.96. Impacts on the right to housing may also be linked to climateinduced migration, especially due to declining agricultural yields, the
destruction of ecosystems, and resource shortages caused by climate
change.*® For instance, the OHCHR notes that “[t]he erosion of livelihoods,
partly caused by climate change, is a main ‘push’ factor for increasing rural
to urban migration,” thereby causing many to “move to urban slums and
informal settlements where they are often forced to build shelters in hazardous
areas.”490
8.97. This is particularly relevant to the Philippines, where many poor
people in urban areas lack access to infrastructure and basic services and live
in settlements in low-lying coastal areas in the cities. The people’s right to
adequate housing is constantly being jeopardized by climate-related impacts
such
as
flash
flooding,
Specifically, petitioners’
landslides,
community
sea-level
witnesses
rise,
and
storm
surges. 47!
from urban poor areas in
Marikina and Rizal -- Mr. Noli Abinales, Mr. Pablo Taon Ill, Ms. Francia
‘® Exhibit “CCCCCCCCC” to “CCCCCCCCC-3,” supra note 15; also see Testimony of Ms. Amalia
Bahian, TSN 11-12 December 2018, pp. 7-15, also available at http://chr.gov.ph/wpcontent/uploads/20 19/04/NICC-TSN-December-I 1-to-12-201 8-Metro-Manila-Philippines.pdf (last
accessed on 12 September 2019).
485 Exhibit “QQQQQQQQQ” to “RQQQQQQQQ-7,” Statement of Ms. Monica Piquero Tan, dated 03
December 2018; also see Testimony of Ms. Monica Piquero-Tan, TSN 11-12 December 201 8, pp. 18-27,
available at http://chr.gov.ph/wp-content/uploads/20 19/04/NICC-TSN-December-1 | -to-12-2018-Metro-
Manila-Philippines.pdf (last accessed on 12 September 2019).
484 Exhibit “MMMMMM” to “MMMMMM-5,”
supra note 400; also see Ubaldo, S., TSN 27-28 September
2018, supra note 422, pp. 6-8.
“85 Exhibit “NNNNNN” to “NNNNNN-S,” Statement of Cristina C. Cocadiz, dated 19 September 2018;
also see Testimony of Ms. Cristina Cocadiz, TSN 27-28 September 2018, pp. 10-25, available at
http://chr.gov.ph/wp-content/uploads/20 19/04/N 1CC-TSN-September-27-to-28-New-Y ork-UnitedStates.pdf (last accessed on 12 September 2019).
486 Bacason, M., supra note 401; also see Testimony of Ms. Marielle Trixie J. Bacason, TSN 6-7 November
2018, pp. 96-108, available at http://chr.gov.ph/wp-content/uploads/2019/04/NICC-TSN-November-6-to-7London-United-Kingdom.
pdf (last accessed on 12 September 2019).
“87 Joint Summary of the Amicus Curiae, supra note 50, p. 26, IPCC ARS WGIII, p. 364.
488 Ibid.
“ Joint Summary of the Amicus Curiae, supra note 50, p. 26, IPCC ARS WGIIL, p. 364.
4° Lofts, K., supra note 375, p. 8, citing A/HRC/10/61, para. 36.
491 Did, p.9.
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