33 i. Right to Life No human right is more fundamental and universal than the inherent right to life. It essentially means the right to exist. Its recognition is enshrined in Article 3 of the United Nations Declarations of Human Rights140 (UDHR), Article 6 of the ICCPR, and in various international treaties and instruments and State constitutions. In the Philippines, it is protected by Article III, Section 1 of the Constitution. UNHRC General Comment No. 36 to Article 6 of the ICCPR recognizes climate change as one of the most pressing and serious threats to life.141 The UNEP further explains that climate change, through sudden onset events, poses a direct threat to human lives and safety, and, through gradual forms of environmental degradation, undermines critical resources that support human life.142 A study commissioned by the Climate Vulnerable Forum found that climate change is responsible for an estimated 400,000 deaths per year due to the direct effects associated with extreme weather events, flooding, heat waves, disease, and water and food insecurity.143 The World Health Organization (WHO) reported that between 1998 and 2017, more than 166,000 people died from brutal heat waves,144 a figure that, given the projected increase of populations145 especially in urban areas where climate models predict intense warming due to continued emissions,146 will exponentially increase in the coming decades. Climate change is also expected to cause approximately 250,000 additional deaths per year between 2030 and 2050 due to an increase in malnutrition, malaria, dengue, diarrhea, and heat stress.147 140 141 142 143 144 145 146 147 United Nations General Assembly, Universal Declaration of Human Rights, G.A. Res. 217 (III) A, U.N. Doc. A/RES/217 (III) (Dec. 10, 1948) [hereinafter UDHR]. United Nations Human Rights Committee, General Comment No. 36 (2018) on Article 6 of the International Covenant on Civil and Political Rights, on the Right to Life, UN Doc. CCPR/C/GC/36 (Oct. 30, 2018) ¶ 62. Michael Burger & Jessica Wentz, Climate Change and Human Rights (United Nations Environment Programme in cooperation with Columbia Law School: Sabin Center for Climate Change Law), available at http://apps.unep.org/publications/index.php?option=com_pub&task=download&file=011917_en (last accessed Nov. 20, 2019). DARA and Climate Vulnerable Forum, Climate Vulnerability Monitor 2012: A Guide to the Cold Calculus of a Hot Planet (Madrid: Fundación DARA Internacional, 2012) (citing Sabin Center for Climate Change Law, supra note 36, at 15). World Health Organization, heatwaves#tab=tab_1. Heatwaves, available at https://www.who.int/health-topics/ Statista Research Department, Urbanization by Continent 2020 (as of 02 December 2020), available at https://www.statista.com/statistics/270860/urbanization-by-continent/. Zhao, L., Oleson, K., Bou-Zeid, E. et al. (2021) Global multi-model projections of local urban climates. Nat. Clim. Chang. 11, 152–7. https://doi.org/10.1038/s41558-020-00958-8 World Health Organization, Quantitative Risk Assessment of the Effects of Climate Change on Selected Causes of Death, 2030s and 2050s (Geneva: World Health Organization, 2014) (citing Sabin Center for Climate Change Law, supra note 36, at 15).