schools continue to operate. The CHRP took a stand against the threats, saying that the same ''would violate the lntemational Humanitarian Law (lHL) that gives protection to noncombatants, civilians, as well as civilian properties and institutions, during armed confliet."6 c. ln August 2018, during a counterinsurgency operation, military forces conducted an aerial strike in the village of Dagohoy in Talaingod, Davao del Nort6, where a Lumad school was situated. An exchange of gunshots soon followed. The attacks reportedly caused trauma to the Lumad school children who were attending classeB in the said school,T d. On 12 December 2018, the 17h Congress approved th€ request of President Duterte to extend martial law in Mindanao until the end of 2019.8 Th6 constitutionality of the extension was subsequently upheld by the Supreme Court of the Philippines.e The CHRP issued a statement, maintaining that the declaration of martial law "should be reserved as an €xtraordinary measure for lawless violence, invasion, or rebellion, as detormined in th€ Constitution, and should never be the norm." The CHRP also rominded the Philippine government to address the grievances of the displaced Lumad communities.l0 e. ln July 2019, the Philippin€ Department of Education ("DepEd") suspended the permits to operate 55 Lumad schools in the Davao region.1lThe suspensions were based on a tinding that the schools deviated from the D6pEd's curriculum and allegedly taught Communist ideologies. The DepEd Regional Office 11 also claimed that the Lumad schools' teaching materials covered the anthem of th€ Communist Naw People's Army, instructions for use of firearms, and strategies for ambush of military troops.l2 4. The suspensions have greatly affected the Lumad children and disrupted their schooling, making them vulnerable to attacks and subjecting them to hara$ment. The suspensions hava also lad to the denial of the Lumad children's basic and fundamental rights to education and self-determination. 5. Other incidents involving the harassment of lPs are as follows: a 6Press relcase ln July 2019, the CHRP launched a motu proprio investigation on a human tratficking caEe involving Lumad victims from Quezon, Bukidnon based on information received from various labor groups. 34 of the Lumad were rescued from a fish pen in Sual, Pangasinan after being lrt'l Humanitsrian Law," tl August 2017, http://ch.gov.pl/bombing-of-lumad-schools-agaiost-intl-humanitarianlaw-cfu/ (Last accessed: 27 fiom the CHRP, "Bombing of Lumad schools against August 20 I 9). I Tlnquirer.net (Mart D. Sambalud), "Air strikes Dear 'Lutrcad' $chool traumatize kids," September 2018, (Last sccessed; httos://newsinfo.inguirer.net/1027059/air-strikes-near-lumad-school-traumatize-kids 27 August 2019). rRappler.com (Mara Cepcda), "Congrcss extends martial law in Minrlanso to end of 2019," 12 December 2018, https r/www. rapp ler. com/nation/2 I 8 733 -conllless-extension-m&dial-law-rldndanao-december-20 I 9 (Last accessed: 27 August 2019). eRappler.com (Lian Buan), "Supreme Court upholds 3d extension of Mindanao martial law," 19 February 2019, https://ww\ .rappler.cor/nation/223839-sqpreme-court-decision-3rd-extcnsion-mindanso-madial-law (Last accessed: 27 August 2019). rostatement from CHRP spokespcrson, Atty. Jacquelitre Ann dc Guia, "On thc Suprcmc Court's dccisiotr oIl thc Mindanao," 20 February 2019, eoustitutiouelity of the third extension of martial law h sta decision-on-the-constitutiomlitv-of-the-third-extension-of-maiialJaw-in-miodalrao/ 'rManila Bulletin (Merlha Hcmando-Malipot), "DepEd explains suspension of 55 Lumad schools," 18 July 2019, nlains-sutbension-of-55Jumad-schools/ (Last accessed: httos://news. mb.com. Dttl2o19/07 I 18/' 27 August 2019). rrlnquirer.net (Matthew Reysio-Cruz), "DepEd shuts down 55 'Lumad' 15 July 2019, (Last accessed: 27 August schools," httos://newsinfo.inquirer.net/ I 141670/deoed-shuts{own-55Jumad-schools 2019).