6 Well-meaning climate change and human rights commitments require more than just text on a website. They should inspire hope that a breakthrough can be achieved and demonstrate that meaningful action is being implemented today. All of the respondents must engage in the national public inquiry and live up to their climate change and human rights commitments, or if they don’t have any yet, make meaningful commitments now. I. ISSUES AND ARGUMENTS RAISED BY THE RESPONDENTS IN THEIR RESPECTIVE RESPONSES TO THE PETITION A. Issues and arguments raised in the responses received by the Petitioners 1.1. Respondents generally contend that: (a) the Honorable Commission did not acquire “personal and subject matter jurisdiction”; (b) the Petition fails to state a “cause of action”; (c) the element of “causation” is non-existent; and (d) the No-Harm Principle or the Trail Smelter case is inapplicable. 1.2. With regard to their argument that the Honorable Commission lacks “jurisdiction,” respondents allege that: a. There was improper service of the Petition and Order requiring respondents to comment/answer, and service was not made to a resident agent; b. Some of them were not particularly named in the Petition, as the entities identified in the package from, and Order of, the Honorable Commission, caption, and tables in the Petition and annexes, were not legal entities or not the registered corporate names of the respondents; c. Some of them were not registered/domiciled in the Philippines and/or transacting/doing business in this jurisdiction; d. The Honorable Commission’s “jurisdiction” is with respect to investigations on human rights abuses involving only civil and political rights; e. The rights invoked by the petitioners, specifically environmental rights, do not fall under civil and political rights;

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