Memorandum for the Petitioners | 21 vires as a matter of Philippines law for the purposes of the current Inquiry. Furthermore, the Commission’s jurisdiction under the Constitution to consider breaches of economic, social and cultural rights in exercising its functions is beyond dispute. Sections 18(6) and 18(7) give the Commission a very broad mandate to, respectively, recommend to Congress effective measures to promote human rights and to monitor the Philippine Government’s compliance with international treaty obligations on human rights. In exercising both of these functions, the Commission is free to determine the manner in which it will inform itself to make such recommendations or to conduct such monitoring, including by conducting a public inquiry. XXX The Supreme Court has also maintained this holistic interpretation of human rights in domestic law, recognizing socio-economic rights as justiciable. XXX Subsequent jurisprudence has maintained both the self-executing character of the right to a balanced and healthful ecology and the correlative obligations to which this right attach. In sum, the legislative provisions on the Commission’s mandate and their interpretation, in line with established Philippine Supreme Court’s case law, leave no doubt over the Commission’s jurisdiction to hear the petition pursuant to each, or any, of its recommendatory or monitoring functions.*? investigation, 4.3. In their Consolidated Reply dated 10 February 2019, petitioners extensively discussed and refuted respondents’ objections to the Honorable Commission’s authority to conduct the investigation against them. All the arguments and discussion contained in said Consolidated Reply relative thereto are hereby adopted and incorporated in this memorandum to avoid needless duplication. 4.4. Significantly, petitioners’ position on this issue of authority to investigate and the Honorable Commission’s action was similarly carried in the various amicus curiae briefs submitted in support of the petitioners and further echoed in the Joint Summary of the Amicus Curiae dated 19 March 2018 submitted by different amici experts. 59 la. 8 See Joint Summary of the Amicus Curiae, supra note 50, pp.1 1-20.