138 It was also stated that “[t]he implementation of the mitigation commitments shall be undertaken through bilateral, regional and multilateral cooperation,” and “market and non-market mechanisms under Article 6 of the Paris Agreement.”594 The NDC is anchored on enhanced access to climate finance, technology transfer and development, and capacity building. Noticeably, the NDC mitigation commitment is 5 percent higher than that indicated in the INDC. The NDC likewise promotes education, public awareness, and meaningful inclusive collaboration with vulnerable sectors, and “upholds the importance of ensuring ecosystems integrity and promoting the country’s obligations on human rights and the rights of indigenous peoples.”595 The Judiciary also plays and continues to play a significant role in environmental protection. In the oft-cited case of Oposa v. Factoran,596 the Supreme Court recognized the right of current and future generations to a balanced and healthful ecology. The Court, in MMDA v. Concerned Residents of Manila mandated the clean-up of Manila Bay through aWrit of Continuing Mandamus597–an order not usually used in environmental cases. In 2009, the Supreme Court issued the Rules of Procedure for Environmental Cases, 598 which introduced the Writ of Kalikasan, a special civil action on behalf of persons whose constitutional right to a balanced and healthful ecology is violated, or threatened with violation, by an unlawful act or omission of a public official or employee, or private individual or entity, involving environmental damage of such magnitude as to prejudice the life, health or property of inhabitants in two or more cities or provinces.599 This procedural remedy allows for a “citizen suit,”600 and permits any Filipino citizen–representing “minors and generations yet unborn”–to file an action 594 Id. 596 Oposa v. Factoran, Jr., G.R. No. 101083, 224 SCRA 792 (1993). 597 Metropolitan Manila Development Authority v. Concerned Residents of Manila Bay, G.R. Nos. 171947-48, 574 SCRA 661 (Dec. 18, 2008). 595 Id. 598 Rules of Procedure for Environmental Cases, A.M. No. 09-6-8-SC (Apr. 29, 2010). 599 Id. (Rule 7). 600 Id. (Part II, Civil Procedure, Rule 2, Section 5. Citizen suit. — Any Filipino citizen in representation of