Memorandum for the Petitioners |104 infrastructure and flooding can leave behind contaminated water, contributing to the spread of waterborne diseases.4” 8.92. In the Philippines, flooding and intense rainfall can damage and contaminate water sources, increasing the prevalence of illness such as diarrhea, which is one of the primary causes of death for children under five.4” On the other hand, the higher incidence of drought is also a major concern for the Philippines, where previous droughts have caused massive crop failures and water shortages.*”4 8. The right to adequate housing*”® 8.93. The UDHR and the ICESCR recognize that all persons have a right to adequate housing, as part of the right to an adequate standard of living.“”° The right to adequate housing entails the right to be free from arbitrary interference with one’s home, privacy and family, and the right to choose one’s residence, to determine where to live, and to have freedom of movement.‘”7 Rising sea-levels, flooding, forest fires, extreme weather events, and other climate-related harms will arbitrarily deprive many individuals of their housing and other property.‘78 8.94. Living testaments to this hardship are most of the community witnesses -- including Ms. Cabe,*”? Ms. Golong,*®° Ms. Gonzales,*#! Ms. “ Joint Summary of the Amicus Curiae, supra note 50, p. 24. “3 Lofts, K., supra note 375, p. 8, citing Javier Bornstein Ortega & Christine Klauth, Climate Landscape Analysis for Children in the Philippines (Makati City: UNICEF Philippines, 2017), p. 20. “74 Joint Summary of the Amicus Curiae, supra note 50, p. 24, citing World Bank (2013), Getting a Grip on Climate Change in the Philippines, p. 24. *? The right to housing is part of the right to an adequate standard of living, see Article 11(1) of the ICESCR. See also UDHR at Art 25(1); CERD at Art 5(e)(iii); CEDAW at Art 14(2); CRC at Art 27(3); 476 UDHR Art. 25; ICESCR Art. 11(1). CRPD at Arts 9(1)(a), 28(1) and (2)(d). 477 Joint Summary of the Amicus Curiae, supra note 50, p.26, citing UN Human Rights Office of the High Commissioner (2009), The Right to Adequate Housing, Fact Sheet No. 21/Rev.1, p. 3. “78 See example cited in the Joint Summary of the Amicus Curiae, supra note 50, p. 26, International Organization for Migration (2009), Migration, Environment and Climate Change: Assessing The Evidence, p. 355. 479 Exhibit “AAAAAAAA” to “AAAAAAAA-6,” Salaysay ni Bb. Veronica V. Cabe, dated 22 October 2018; also see Cabe, T., supra note 2, pp. 108-118. “8° Exhibit “LLLL” to “LLLL-4,” supra note 11; also see Testimony of Arthur S. Golong, TSN 29-30 August 2018, pp. 5-39, available at http://chr.gov.ph/wp-content/uploads/20 19/04/NICC-TSN-August-29to-30-2018-Metro-Manila-Philippines.pdf (last accessed on 12 September 2019). “8! Gonzales, H., supra note 15 and 433, pp. 45-59.