60
programs initiated by the government were not gender-inclusive, recognizing only
cisgender orientations.287
The lack of data on the impact of disasters caused by climate change on LGBTQIA+
people worldwide exacerbates their plight, making them “largely invisible in relief
and development programs.”288
x. Right to Safe, Clean, Healthy and Sustainable Environment
On 8 October 2021, during its forty-eighth session, the United Nations Human
Rights Council adopted the resolution on the Human Right to a Safe, Clean, Healthy
and Sustainable Environment. The resolution “recognizes the right to a safe, clean,
healthy and sustainable environment as a human right that is important for the
enjoyment of human rights.”289 This recognition is borne out, among others, of the
acknowledgement of the
the impact of climate change, the unsustainable management
and use of natural resources, the pollution of air, land and water,
the unsound management of chemicals and waste, the resulting
loss of biodiversity and the decline in services provided by
ecosystems interfere with the enjoyment of a safe, clean,
healthy and sustainable environment, and that environmental
damage has negative implications, both direct and indirect, for
the effective enjoyment of all human rights.290
The recognition of this human right affirms the Filipinos’ constitutionallyguaranteed right to a balanced and healthful ecology in accord with the rhythm and
harmony of nature.291 However, with climate change, this rhythm and harmony has
been disrupted. Lowell Factor recounted how corals, once “big and colorful” and
July 30, 2021).
287
Id. at 5.
288
Zoe Tabary, Women, LGBT People ‘Invisible’ Victims of Disasters–Experts, Thomson Reuters
Foundation News, Mar. 8, 2018, available at https://news.trust.org/item/20180308114259-otaio/.
289
United Nations Human Rights Council, Draft Resolution: Promotion and Protection of All Human
Rights, Civil, Political, Economic, Social and Cultural Rights, Including the Right to Development,
A/HRC/48/L.23.1, available at https://undocs.org/a/hrc/48/l.23/rev.1.
290
Id.
291
Phil. Const. art. II, § 16.
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