Amicus Curiae Brief presented by ClientEarth 21 November 2016 substantive issues raised by the Petition.10 Many of these companies have instead advanced technical arguments challenging the Commission's jurisdiction to conduct the investigation. Such assertions display a fundamental misunderstanding of the role and powers of the Commission. 15. For the reasons set forth in this section, the Commission should ignore such technical objections to its investigation, and should continue to fulfil its constitutional mandate to investigate, monitor, and make recommendations in relation to human rights violations in the Philippines.11 16. Companies who have not responded to the substance of the Petition should do so promptly to facilitate a fair investigation of both the past and likely future violations of human rights that will result from the unchecked and continued emissions of greenhouse gas emissions from their operations and products. 3.1 Powers and functions of the commission 17. The first and most crucial matter requiring clarification relates to the nature and powers of the Commission and its jurisdiction to conduct an investigation into the responsibility of the groups of companies known as the investor-owned Carbon Majors (as defined in the Petition and in particular Annex C to the Petition). 18. The Commission is an independent office created by Section 17(1) of Article 13 of the 1987 Constitution of the Republic of the Philippines (Constitution). The 10 https://business-humanrights.org/en/fossil-fuel-cos-respond-to-petition-with-philippines-human-rights-commission-on-human-rights-climate-changeimpacts 11 Notably, many of the groups of companies named in the Petition made various pledges and commitments before the adoption of the Paris Agreement through the UNFCCC's Non State Actor Zone for Climate Action platform, and accordingly recognise the risks climate change poses to the environment and human wellbeing. See here for details: http://climateaction.unfccc.int/ 9