7 B. f. The petitioners cannot rely on the UN Guiding Principles and Maastricht Principles, as they are non-binding; g. The Honorable Commission is not a quasi-judicial body— it has no quasi-judicial or adjudicative power; h. The Congress, through the enactment of the Human Security Act, expressly acknowledges that the Honorable Commission’s “jurisdiction” is confined only to violations of civil and political rights; i. The Congress does not consider the Honorable Commission to have any jurisdiction over environmental, climate change, or socio-economic and cultural matters, considering that the Honorable Commission was not included among the government agencies composing the advisory board of the Philippine Climate Change Commission (CCC). Further, by taking cognizance of the case, the Honorable Commission usurps the functions of the CCC; and j. Respondent Peabody Energy Corporation (“Peabody”) is precluded under the U.S. Bankruptcy Code from responding to the Honorable Commission’s Order and the Petition, and from participating in the present proceedings. Issues and arguments raised in the responses received by the Business & Human Rights Resource Centre 1.3. With respect to the responses received by the Business & Human Rights Resource Centre (“BHRRC”), except respondent Rio Tinto, all others similarly question the Honorable Commission’s “jurisdiction” and that the confidentiality rules prevent respondents from disclosing their response to the Petition. Some of the respondents also argue that their positions on climate change and human rights are adequate. Please see Annex “A” for a list of respondents that submitted answers and comments to the petitioners and the Business Human Rights Resource Centre. 1.4. As will be discussed below, respondents’ issues and arguments are unmeritorious and even contrary to the Philippine Constitution and applicable domestic and international laws, rules, and jurisprudence.

Select target paragraph3