Memorandum for the Petitioners | 106 Encinas,‘ Mr. Isagani Molina, and Mr. RJ de Ramos? -- who testified to the pain caused by having one’s house repeatedly flooded and having to be relocated after a typhoon has hit their homes— trauma which they are still suffering from after so many years. 8.98. In the Philippines, severe storms and flooding events linked to climate change have already displaced millions of people from their homes. Super typhoon Haiyan displaced more than four million people and damaged or destroyed more than one million homes.“ 8.99. Displacement due to sea level rise is another major concer in the Philippines, due to the rapid increase in sea levels and the number of people who live on the coast.” On the other hand, climate-related displacement from rural areas to cities may also increase due to decreased agricultural yields and inadequate job opportunities in the agricultural sector, putting additional pressure on depressed urban areas and mega cities.4% 9. The right security*”® to work *” and social 8.100.Climate change deprives individuals, such as farmers and fisherfolks, of their livelihoods and, in general, disrupts the right to work by provoking significant economic transformations. For example, the bleaching of coral reefs and the diminution of wildlife stocks may cause the tourism industry to decline, leading to loss of employment. 8.101.Extreme weather events, which lead to the destruction of infrastructure, displacement, and damage to crop yields, will also have important economic consequences and thereby affect the right to work. In the context of the Philippines, the United Nations International Children’s Emergency Fund (UNICEF) has noted that “[s]ubsistence livelihoods in rain“ Exhibit “ZZZ,” Mga Salaysay nina Gg. Manuel A. Abinales, Gg. Pablo Taon III, at Gng. Francia M. Encinas; also see Testimonies of Ms. Francia Ensinas, Mr. RJ de Ramos, Mr. Isagani Molina, Mr. Pablo Taon III, and Mr. Manuel Abinales, TSN dated 23-24 May 2018, pp. 228-255. “ Exhibit “YYY” to “YYY-2,” Mga Salaysay nina Gg. Isagani Molina at RJ de Ramos; also see Testimonies of Ms. Francia Ensinas, Mr. RJ de Ramos, Mr. Isagani Molina, Mr. Pablo Taon III, and Mr. Manuel Abinales, TSN 23-24 May 2018, pp. 228-255. 44 Angela Sherwood et al. (2014), Resolving Post-Disaster Displacement: Insights from the Philippines After Typhoon Haiyan, available at https://www. brookings.edu/wp-content/uploads/2016/06/ResolvingPostDisasterDisplacementInsights-from-the-Phi lippines-after-Typhoon-Haiyan-June-2015.pdf (last accessed 06 September 2019). “5 Joint Summary of the Amicus Curiae, supra note 50, p. 26. “6 Ibid. Also see Effects of Typhoon Yolanda (Haiyan), p. 3, available at http://www.ndrrmc.gov.ph/attachments/article/ 1329/Effects_of_Typhoon_YOLANDA_(HAIYAN), SitRep _No_10_10NOV2013_0600H.pdf (last accessed on 12 September 2019). 497 ICESCR, Arts 6-8; ICCPR, Art 8(3)(a); CERD, Art 5(e)(i); CEDAW, Art 1 1(1)(a); CRC, Art 32; International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, December 18, 1990, 2220 UNTS 3, Arts 11, 25, 26, 40, 52 and 54. “°8 ICESCR at Art 9; CERD at Art 5(e)(iv), CEDAW at Art 11 and 14; CRC at Art 26.

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