100 incorporated into statutory law, including non-binding international instruments, such as the UDHR. The UDHR, for example, is a resolution and not a treaty. Thus, during its adoption by the United Nations General Assembly in 1948, it was not considered as a binding instrument.467 Yet, in 1951 or merely three years after its adoption, and long before the UDHR was recognized by the international community to have achieved the status of customary international law, the Supreme Court in the landmark case of Mejoff v. Director of Prisons, adopted the UDHR through the incorporation clause of the 1935 Constitution, to wit: Moreover, by its Constitution (Art. II, Sec. 3) the Philippines “adopts the generally accepted principles of international law as part of the law of Nation.” And in a resolution entitled “Universal Declaration of Human Rights” and approved by the General Assembly of the United Nations of which the Philippines is a member, at its plenary meeting on December 10, 1948, the right to life and liberty and all other fundamental rights as applied to all human beings were proclaimed. It was there resolved that “All human beings are born free and equal in degree and rights” (Art. 1); that “Everyone is entitled to all the rights and freedom set forth in this Declaration, without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion, nationality or social origin, property, birth, or other status” (Art. 2): that “Everyone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental rights granted him by the Constitution or by law” (Art. 8); that “No one shall be subjected to arbitrary arrest, detention or exile” (Art. 9); etc.468 This was followed by similar pronouncements of incorporation of the UDHR as part of Philippine law in Borovsky v. Commissioner of Immigration,469 Chirskoff v. Commissioner of Immigration,470 and Andreu v. Commissioner of Immigration.471 Admittedly, the Supreme Court, six years thereafter, recanted its adoption of the UDHR in 467 James Crawford, Brownlie’s principles of public international law (8th ed.) (2012), at 636-7. 468 Boriss Mejoff v. The Director of Prisons, G.R. No. L-4254 (Sep. 26, 1951). 470 Vadim Chirskoff v. The Commissioner of Immigration and The Director of Prisons, G.R. No. L-3803 (Oct. 26, 1951). 469 471 Victor Borovsky v. The Commissioner of Immigration and The Director of Prisons, G.R. No. L-4352 (Sep. 28, 951). Charles Andreu v. The Commissioner of Immigration and The Director of Prisons, G.R. No. L-4253 (Oct. 31, 1951).