101 Ichong v. Hernandez.472 But it pivoted back in Reyes v. Bagatsing, proudly declaring that at the time when other nations merely considered the UDHR as aspirational, the Philippines had already given it binding force in its jurisdiction, thus: “The Philippines renounces war as an instrument of national policy, adopts the generally accepted principles of international law as part of the law of the land, and adheres to the policy of peace, equality, justice, freedom, cooperation, and amity with all nations.” The Philippines can rightfully take credit for the acceptance, as early as 1951, of the binding force of the Universal Declaration of Human Rights even if the rights and freedoms therein declared are considered by other jurisdictions as merely a statement of aspirations and not law until translated into the appropriate covenants. In the following cases decided in 1951, Mejoff v. Director of Prisons, 90 Phil. 70; Borovsky v. Commissioner of Immigration, 90 Phil. 107; Chirskoff v. Commissioner of Immigration, 90 Phil. 256; Andreu v. Commissioner of Immigration, 90 Phil. 347, the Supreme Court applied the Universal Declaration of Human Rights.473 2. All Entities within the Carbon Majors’ Value Chain may be Compelled to Undertake Human Rights Due Diligence and Provide Remediation The corporate responsibility to refrain from contributing to climate change impacts that impair the full enjoyment of human rights extends not only to the whole group of companies of each Carbon Major in recognition of the enterprise theory of corporate personhood,474 but also to all business enterprises in each of the Carbon Majors’ respective value chains.475 Accordingly, the Carbon Majors and business enterprises that cause, contribute to or are linked to adverse climate-related human rights impacts, “need to know and be able to show” that they respect human rights.476 This they can do by undertaking a human rights due diligence process as set forth in Principles 16 to 21 of the UNGP-BHR. 472 473 Lao Ichong, in his own behalf and in behalf of other alien residents, corporations and partnerships adversely affected by Republic Act No. 1180 v. Jaime Hernandes, et. al., G.R. No. L-7995 (May 31, 1957). Jose B.L. Reyes, in behalf of the Anti-Bases Coalition (ABC) v. Ramon Bagatsing, as Mayor of Manila, G.R. No. L-65366 (Nov. 9, 1983), n. 34. 474 See Amicus Curiae Brief of ClientEarth, supra note 27, at 47-49. 475 UNGP-BHR, supra note 313 (Principle 13). 476 Id. (Principle 15).

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