notes that, in case there is any question that the rights mentioned by the Petitioners are not all civil and political rights, courts around the world as well as international human rights bodies have determined that the right to life encompasses many of the rights invoked by the Petitioners, including the right to live in a healthy environment. 18 In addition, APF and GANHRI note that the Commission’s mandate to investigate violations of social, cultural, and economic rights is corroborated by the case law of the Supreme Court of the Philippines.19 The Court has applied the Universal Declaration of Human Rights (UDHR) as “generally accepted principles of international law as part of the law of the Nation” to investigate violations of a range of rights enshrined in the Declaration, including economic, social, and cultural rights.20 For instance, in Villar v. TIP, the Court annulled a college’s expulsion of students for their participation in protests, relying among others on their right to education enshrined in the UDHR. 21 The Supreme Court has also maintained this holistic interpretation of human rights in domestic law, recognizing socio-economic rights as justiciable.22 In Oposa v. Factoran, Jr., the Supreme Court held that the constitutional right to a balanced and healthful ecology “unites” with the right to health (art. II, secs.16 and 15 of the Constitution) imposing “the correlative duty to refrain from impairing the environment,” whereas its “denial or violation … by the other who has the correlative duty or obligation to respect or protect the same gives rise to a cause of action.” 23 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 attaches. 24 IV. The Commission has authority to investigate human rights violations committed by the respondents, even though they are headquartered outside the Philippines ClientEarth and ELAW note that the Commission is not starting a formal adjudicative proceeding, but merely opening an investigation and granting respondents an opportunity to be heard. Therefore, questions about whether the Commission has jurisdiction over the respondents are misplaced.25 However, both briefs also explain that if there is any question, the 18 See id. at pgs. 7-13. See APF & GANHRI brief, at ¶ 6. 20 Mejoff v. Dir. of Prisons, G.R. No. L-4254 (S.C. Sept. 26, 1951) (Phil.) (en banc); Borovsky v. Comm’r of Immigration, G.R. No. L- 4352 (S.C. Sept. 28, 1951) (Phil.) (en banc); Villar v. Tech. Inst. of the Philippines, G.R. No. L-69198 (S.C. Apr. 17, 1985) (Phil.) (en banc); Remoto v. Comm’n on Elections, G.R. No. 190582 (S.C. Apr. 8, 2010) (Phil.) (en banc). See APF & GANHRI brief, at ¶ 6. 21 Villar, G.R. No. L-69198. See APF & GANHRI brief, at ¶ 6. See also Merlin M. Magallona, The Supreme Court and International Law: Problems and Approaches in Philippine Practices, 85 PHIL. L. J. 1, 1, 62 (2010). 22 See APF & GANHRI brief, at ¶ 7. 23 Oposa v. Factoran, Jr., G.R. No. 101083, 224 S.C.R.A. 792 (S.C. July 30, 1993) (Phil.) (en banc). 24 See Elizabeth Barrett Ristroph, The Role of Philippine Judges in Establishing the Environmental Rule of Law, 42 ENVTL. L. REP. 2 (2012), 1, at 16, n. 77, available at https://works.bepress.com/elizabeth_ristroph/3/; see also Supreme Court Decision of December 8, 2015 on the consolidated cases Int’l Serv. for the Acquisition of AgriBiotech Applications, Inc. v. Greenpeace Southeast Asia (Philippines), G.R. No. 209271, Envtl. Mgmt. Bureau of the Dep’t of Env’t v. Greenpeace Southeast Asia (Philippines), G.R. No. 209276; Univ. of the Philippines Los Baños Foundation, Inc. v. Greenpeace Southeast Asia (Philippines), G.R. No. 209301; Univ. of the Philippines v. Greenpeace Southeast Asia (Philippines), G.R. No. 209430 (S.C. Dec. 8, 2015) (Phil.) (en banc), http://sc.judiciary.gov.ph/pdf/web/viewer.html?file=/jurisprudence/2015/december2015/209271.pdf; see APF & GANHRI brief, at ¶ 7. 25 See ClientEarth brief, at ¶ 23. 19 14