Amicus Curiae Brief presented by ClientEarth 21 November 2016 23. Given that the Commission is not capable of exercising judicial power, the scope of the investigation that the Commission may conduct in accordance with Section 18(1) of Article 13 is not limited by legal rules governing the exercise of judicial power. This includes principles of international law limiting a nation-state's judicial power to activities that are connected with its territory including: a. the principle of state sovereignty; and b. the principle of territoriality. 24. This interpretation is confirmed by section 18(c) of Article 13 of the Constitution, which refers to the rights of Filipino citizens residing abroad. The scope of the investigatory function of the Commission is arguably not intended to be limited to violations arising from acts occurring within the territory of the Philippines. This flexible interpretation would support the Commission's function as an investigative fact-finding body tasked with protecting and promoting the human rights of all Filipino citizens. 25. In any event, national judicial bodies are entitled to, and frequently do, assert jurisdiction over activities that cause harm within their own territory, even in circumstances where that damage or harm resulted from events occurring outside that territory.12 If the Commission accepts that climate change affects human rights within the Philippines, it must be empowered to investigate the cause of those violations, regardless of whether that harm originated outside of the Philippines. This 12 Tolofson v. Jenssen, [1994] 3 S.C.R. 1022, para. 43 (Canada), Dow Jones & Co Inc v Gutnick (2002) 210 CLR 575 (Australia); Edition Ecosociete Inc. v. Banro Corp, 2012 SCC 18 (Canada); Pakootas v. Teck Cominco Metals, Ltd., 646 F.3d 1214 (9th Cir. 2011). 13