Memorandum for the Petitioners | 20 Iv THE HONORABLE COMMISSION’S AUTHORITY TO INVESTIGATE AND GRANT THE RELIEFS PRAYED FOR BY THE PETITIONERS The Honorable Commission’s authority to investigate human rights violations and/or threats thereof is unequivocal and explicitly mandated by no less than the 1987 Philippine Constitution, the Honorable Commission’s Omnibus Rules, and various international human rights and environmental agreements to which the Philippines is a signatory 4.1. Respondents are domiciled in many countries around the world, from the United States to South Africa to Australia. The corporate groups’ operations take place in an even greater number of countries. The products are sold and burned in an even larger number of countries. Yet the harm at issue in this National Inquiry is occurring here, in this country, our home, the Philippines. 4.2, The National Inquiry pronouncements December 2017% authority of the Honorable Commission to conduct this is — and should be — a settled issue considering its during the preliminary conference of the parties held on 11 and the opening of the first public hearings on 27 March 2018,%° and in its closing press release.5” The following pronouncements during the preliminary conference® are enlightening— In accordance with the well-established doctrine of compétence de la compétence, it is for the Commission to determine the scope of its own jurisdiction. Most compellingly, the Commission’s jurisdiction to adopt its Omnibus Rules of Procedure has not been the subject of domestic legal challenge. Accordingly, the Omnibus Rules in their current form are demonstrably intra 55 See Opening Remarks of the Focal Chairman of the NICC, Commissioner Roberto Eugenio T. Cadiz, TSN dated 11 December 2017, pp. 9-12. 56 See Opening Remarks of Chairman Jose Luis Martin C. Gascon, Transcript of Proceedings: National Inquiry on the Impact of Climate Change on the Human Rights of the Filipino People, and the Responsibility of the “Carbon Majors,” if any, First Hearing, March 27 to 28, 2018, pp. 2-5 (hereinafter, “TSN dated 27-28 March 2018”), also available at http://chr.gov.ph/wp-content/uploads/2019/04/NICCTSN-March-27-t 1 8-Metro-Manila-Phi o-28-20 lippines.pdf (last accessed on 12 September 2019). 57 Commission on Human Rights (CHR) Press Release (13 December 2018), CHR concluded landmark inquiry on the effects of climate change to human rights; expects to set the precedent in seeking climate Justice,” available at https://essc.org.ph/content/wpcontent/uploads/2019/03/CHR_concluded_landmark_inquiry_on.pdf (last accessed on 12 September 2019). 38 TSN dated 11 December 2017, supra note 55.