Memorandum for the Petitioners | 93 Sendong (“Washi”), are testaments to the effect on the right to life of these more intensified storms. 8.60. We do not want to count dead bodies again, much less do we want to be part of the bodies to be counted in the aftermath of a typhoon, drought, or other extreme weather events. 8.61. To reiterate, as the Philippine constitutionalist, Fr. Joaquin Bernas, has emphasized: “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. 3. The right to life is the right to a good life.“ The right to a clean and healthy environment (or the right to a balanced and _ healthful ecology), including the right to a safe climate 8.62. The right to a clean and healthy environment, or the right to a balanced and healthful ecology, has increasingly become recognized as an independent human right by over 155 national constitutions and laws. 8.63. dimensions, both present distinct from The right to a healthy environment has individual and collective in the sense that it expresses a universal interest that is owed to and future generations. The right to a healthy environment is the environmental dimensions of other rights and protects the elements of the environment (e.g., forests, rivers, seas, etc.). The right to a healthy environment is connected to other rights, including the right to life, health, and personality integrity.” 8.64. The right to a healthy environment also includes the right to a safe climate, as stated by the U.N. Special Rapporteur on the Right to a Healthy Environment in his 2019 Safe Climate Report: climate, The substantive elements of this right include a safe clean air, clean water and adequate sanitation, healthy and sustainably produced food, non-toxic environments in which to live, work, study and play, and healthy biodiversity and ecosystems. These elements are informed by commitments made under international “° Bernas, J.G. (2003), The 1987 Constitution of the Republic of the Philippines: A Commentary, 2003 ed.; Manila: Rex Book Store, p. 110. “°° See United Nations Human Rights Council (08 January 2019), Issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment, Report of the Special Rapporteur, A/HRC/40/55, para. 16, available at https://undocs.org/en/A/HRC/40/55 (last accessed 12 September 2019). 407 Exhibit “CCCC” to “CCCC-6,” Statement of Dr. Marcos Orellana, p. 2.