Memorandum for the Petitioners | 10
3.3.
conducted
granted -subsequent
in relation
Four (4) months thereafter, during a preliminary conference
by the Honorable Commission, petitioners sought -- and were
leave to file an Amended Petition dated 21 April 2016 due to
important events that happened and critical information released
to the subject matter of the Petition.*° For purposes of this
memorandum, Petition here refers to the Amended Petition, which supersedes
the first one filed.
3.4.
In an Order dated 21 July 2016, the Honorable Commission
enjoined respondent Carbon Majors to file their respective comments or
answers within forty-five (45) days from receipt of the Petition.
3.5.
On various dates, the Honorable
Commission
received fifteen
(15)3! comments or advice of receipt or delivery of entry and four (4)?
om
an
wk
wn
registry return receipts out of the forty-seven (47) respondents® summoned,
while petitioners received fourteen (14) responses, two (2) of which came
from respondent Repsol, S.A. and Repsol Oil & Gas Canada Inc. The
responses which petitioners received are as follows:
9.
10.
11.
12.
13.
14.
Apache Corporation;
CEMEX S.A.B. de C.V.;
Chevron;
ConocoPhillips;
ExxonMobil Petroleum & Chemical Holdings, Inc.
Philippine Branch;
LafargeHolcim and Lafarge SA, Holcim Group Services
Ltd., and Holcim Technology Ltd.;
Marathon Oil Corporation;
Peabody Energy Corporation;
PricewaterhouseCoopers LLP (liquidators of UK Coal);
Repsol, S.A. and Repsol Oil & Gas Canada Inc.;
Repsol, S.A. and Repsol Oil & Gas Canada Inc.;
Shell Company of the Philippines, Limited (SCPL) and
Royal Dutch Shell PLC (RDS);
Taiheiyo Cement Corporation; and
Total Philippines Corporation (TPC)
announces-public-hearings-of- fossil-fuels-firms-over-climate-human-rights-impacts (last accessed on 12
September 2019).
3° See Greenpeace Southeast Asia — Philippines’s website for electronic versions of the submissions and
other documents relative to the National Inquiry, supra note 1.
3! See Transcript of Stenographic Notes (TSN) of the Meeting or Conference of the Parties dated I1
December 2017 (hereinafter, “TSN 11 December 2017”): (1) OMV Aktiengesellschaft (OMV Group), (2)
Chevron Geothermal Services Company, (3) Chevron Kalinga Ltd., (4) Chevron Malampaya LLC, (5)
Chevron Philippines, Inc., (6) Chevron Holdings, Inc., (7) Eni S.p.A, (8) Murphy Oil Corporation, (9)
Encana Corporation, (10) Arch Coal, (11) Consol Energy Inc., (12) BG Group PLC, (13) Hess Corporation,
(14) RWE Konzern, and (15) Devon Energy, pp. 19-21 (hereinafter, “TSN 11 December 2017”).
32 (1) Apache Corporation, (2) Marathon Oil Corporation, (3) Conoco-Phillips Corporation, on 26 October
2017; and (4) Anglo-American Exploration.
3 For a description of the number of respondents, see supra note 17.