Precaution espouses prudence where risk is uncertain, but plausible. It is an addition to two basic tenets of problem-solving: curing problems and preventing them. Under a curative approach, the harm has already been realized, and measures are created to reverse the harm, or require compensation for the costs associated with harm. Under the preventive approach, measures are taken to prevent known risks from materializing into actual harm. Precaution requires even greater diligence than prevention, by calling for measures to safeguard the environment even if the occurrence of harm is uncertain. The precautionary principle affirms the need for urgent measures given the unpredictable patterns of the environment, and the harm resulting from its abuse.88 In a recent landmark ruling on the precautionary principle, our highest court explained: An application of the precautionary principle to the rules on evidence will enable courts to tackle future environmental problems before ironclad scientific consensus emerges.89 Furthermore, when features of uncertainty, possibility of irreversible harm, and possibility of serious harm coincide, the case for the precautionary principle is strongest according to the Supreme Court; and it advises: !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 88 Sub-committee on the Rules of Procedure for Environmental Cases, Rules of Procedure for Environmental Cases, Apr. 29, 2010 at 82. 89 See Supreme Court Decision, dated December 8, 2015, on the consolidated cases ISAAA v. Greenpeace Southeast Asia (Philippines), et al., G.R. No. 209271, Environmental Management Bureau of the Department of Environment and Natural Resources, Bureau of Plant Industry and Fertilizers and Pesticides Authority of the Department of Agriculture v. Greenpeace Southeast Asia (Philippines) et al., G.R. No. 209276; University of the Philippines Los Banos Foundation, Inc. v. Greenpeace Southeast Asia (Philippines), G.R. No. 209301; and University of the Philippines v. Greenpeace Southeast Asia (Philippines), G.R. No. 209430, at 100. ! ! ! ! ! 39 !

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