Primer

International accepted principles: Jus Cogens

1. Piracy.
2. Slavery and the slave trade.
3. Genocide.
4. Hijacking of air traffic.
5. Political terrorism abroad, including terroristic activities.
6. Recourse to war, except in self-defense.
7. Threat or use of force against the territorial integrity or political
independence of another State (intervention).
8. Armed aggression.
9. Recognition of situations brought about by force, including fruits
of aggression
10. Treaty provisions imposed by force.
11. War crimes.
12. Crimes against peace and humanity.
13. Offenses against the peace and/or security of mankind.
14. Dispersion of germs with a view to harming or extinguishing
human life.
15. All methods of mass destruction (including nuclear weapons)
used for other than peaceful purposes.
16. Contamination of the air, sea, or land with a view to making it
harmful or useless to mankind.
17. Hostile modification of weather.
18. Appropriation of outer space and/or celestial bodies.
19. Disruption of international communications with a view to
disturbing the peace.
20. Economic warfare with the purpose of upsetting:
(a)The world’s banking systems;
(b)The world’s currencies;
(c) The world’s supply of energy; or
1
(d)The world’s food supply.

1
​Marjorie M. Whiteman, ​Jus Cogens in International Law, with a Projected List​, 7 ​GA. J. INT’L &
COMP. L.​ 609 (1977).http://digitalcommons.law.uga.edu/gjicl/vol7/iss2/6
Legal Opinion
Yes to the imposition of Death Penalty in the Philippines
The re-imposition of the death penalty in the Philippines is not
in violation with our commitment with the Universal Declaration of
Human Rights.
In its international context, the Philippines are party to 8 of the 9
core international human rights treaties. The right to life is at the
center of these international treaties and the Universal Declaration of
2
Human Rights.
The Universal Declaration of Human Rights was drafted by
representatives of all regions of the world and encompassed all legal
traditions. Formally adopted by the United Nations on December 10,
1948, it is the most universal human rights document in existence,
delineating the thirty fundamental rights that form the basis for a
democratic society. Following this historic act, the Assembly called
upon all Member Countries to publicize the text of the Declaration
and “to cause it to be disseminated, displayed, read and expounded
principally in schools and other educational institutions, without
3
distinction based on the political status of countries or territories.”
However, the Universal Declaration of Human Rights is not
legally binding even though it has become binding as a part of
customary international law. As stated in the Supreme Court of the
United States in the case of Sosa v Alvarez-Machain (2004) the
Declaration “does not of its own force impose obligations as a matter
4
of international law.” Hence, it would tantamount that it does not
necessarily form part of the domestic law of the states that made their
commitment to it.
There are 58 countries that still have death penalty as a capital
punishment. Among these countries, there are 55 out 58 states who
are member states of the United Nations that still implements death
penalty. United States of America is one of those states and is a
permanent member of the UN. As we can infer from this, the UDHR is
certainly not binding and it is safe to say that the Philippines can
5
definitely re-impose the death penalty.

2
balayph.net. “Fact Sheet: Note on the Death Penalty and the Philippines.” Fact Sheet: Note on
the Death Penalty and the Philippines - BALAY Rehabilitation Center,
balayph.net/news-events/features-and-articles/128-fact-sheet-note-on-the-death-penalty-and-the-
philippines-2.
3
“UN Universal Declaration of Human Rights.” United for Human Rights,
www.humanrights.com/what-are-human-rights/universal-declaration-of-human-rights/.
4
​“Sosa v. Alvarez-Machain, 542 U.S. 692 (2004).” ​Justia Law​,
supreme.justia.com/cases/federal/us/542/692/.
5
“Home.” United Nations, United Nations, www.un.org/en/index.html.
 If we would try to look at our Constitution, it was one of the
established rules in the Philippines. The re-imposition of the death
penalty would help to lessen the costs of the government c​ompared
to the costs of life imprisonment because they will be given the
expenses of food, health care and other costs that will sustain their
6
lives. It would be impractical for the government to spend so much to
keep alive those criminals who dared to commit heinous crimes.
Doing such would be beneficial not just to the government but also to
the other inmates confined in our overly populated penal facilities.
The government should focus on the aspect that needs to be
addressed, for example, poverty. Instead of keeping those who
committed heinous crimes, why don’t we help those who are really in
need, those who have less in life? That is more a pressing issue that
should be addressed with.
Therefore, on the question that can we validly re-impose the
death penalty in the Philippines, as concluded above, it is in
affirmation because the Universal Declaration of Human Rights is not
in itself binding and the Philippines can, for itself, decide whether to
conform or not.

6
Flores, Marydel Mitch. “Death Penalty Pros and Cons in the Philippines.” Reporter.PH, 26 Sept.
2017, reporter.ph/death-penalty-pros-and-cons-in-the-philippines/.
Case Digest
Philippines v China: Territorial Arbitration

Facts:
The Philippines instituted an arbitration case against China
basing its claim under the 1982 United Nations Convention on the
Law of the Sea (UNCLOS). Since the Philippines and China have
ratified the Convention. Nevertheless, China has consistently stated
its view on the lack of jurisdiction of the Tribunal on the matter.

The arbitration concerns disputed between the parties

regarding the legal basis of maritime rights and entitlements in the
South China Sea, the status of certain geographic features in the
South China Sea, and the lawfulness of certain actions taken by
China in the South China Sea.

Issue:
Whether or not the Tribunal has jurisdiction

Ruling:
Yes. Article 288 of the Conventions states that “In the event of a
dispute as to whether a court or tribunal has jurisdiction, the matter
7
shall be settled by decision of that court or tribunal.” Therefore, the
Tribunal has jurisdiction over the matter.

7
​Magaso, joan. “RP v China Digest.” ​Scribd,​ Scribd, 13 Aug. 2016,
www.scribd.com/document/321059040/RP-v-China-Digest.
Primer
ASEAN treaties basic principles

(a) AIMS AND PURPOSES

As set out in the ASEAN Declaration, the aims and purposes of

ASEAN are:

1. To accelerate the economic growth, social progress and cultural

development in the region through joint endeavours in the spirit
of equality and partnership in order to strengthen the foundation
for a prosperous and peaceful community of Southeast Asian
Nations;
2. To promote regional peace and stability through abiding respect
for justice and the rule of law in the relationship among
countries of the region and adherence to the principles of the
United Nations Charter;
3. To promote active collaboration and mutual assistance on
matters of common interest in the economic, social, cultural,
technical, scientific and administrative fields;
4. To provide assistance to each other in the form of training and
research facilities in the educational, professional, technical and
administrative spheres;
5. To collaborate more effectively for the greater utilization of their
agriculture and industries, the expansion of their trade,
including the study of the problems of international commodity
trade, the improvement of their transportation and
communications facilities and the raising of the living standards
of their peoples;
6. To promote Southeast Asian studies; and
7. To maintain close and beneficial cooperation with existing
international and regional organizations with similar aims and
purposes, and explore all avenues for even closer cooperation
8
among themselves.

​ undamental principles as contained in the Treaty of

(b) F
Amity and Cooperation in Southeast Asia (TAC) of 1976:

1. Mutual respect for the independence, sovereignty, equality,

territorial integrity, and national identity of all nations;

8
“Overview.” ASEAN | ONE VISION ONE IDENTITY ONE COMMUNITY,
asean.org/asean/about-asean/overview/.
 2. The right of every State to lead its national existence free from
external interference, subversion or coercion;
3. Non-interference in the internal affairs of one another;
4. Settlement of differences or disputes by peaceful manner;
5. Renunciation of the threat or use of force; and
9
6. Effective cooperation among themselves.

9
“Overview.” ASEAN | ONE VISION ONE IDENTITY ONE COMMUNITY,
asean.org/asean/about-asean/overview/.
Primer
Dramatic midnight vote: ICC

More than fifty years after the Nuremberg trials, the

international community has established a permanent International
Criminal Court (ICC). The dramatic midnight vote in Rome on July 17,
1998, called by the United States of America, overwhelmingly
approved the statute for the ICC by 120 votes to seven, with
twenty-one abstentions. The vote was a historical breakthrough and
the message sent out from Rome is an unequivocal stop to impunity
10
for grave human rights violations.
However, a closer look at the Rome Statute brings us quickly
back to the world of complex legal technicalities and insufficiencies, a
product of the “spirit of compromise” hanging over the diplomatic
negotiations at the Food and Agriculture Organization building in
Rome. The Rome Statute is not a dogmatically refined international
model penal and procedural code. It could not be. But it is an attempt
to merge the criminal justice systems of more than 150 States into
one legal instrument that was more or less acceptable to every
delegation present in Rome. This applies to all parts of the Statute,
11
but in particular to Part 3, which is entitled “General Principles.”
As to the exercise of jurisdiction, it is provided for in Article 5 of
ICC statute that “The jurisdiction of the Court shall be limited to the
most serious crimes of concern to the international community as a
whole. The Court has jurisdiction in accordance with this Statute with
respect to the following crimes:
(a) The crime of genocide;
(b) Crimes against humanity;
(c) War crimes;
12
(d) The crime of aggression.”

10
Ambos, Kai. “GENERAL PRINCIPLES OF CRIMINAL LAW IN THE ROME STATUTE.”
GENERAL PRINCIPLES OF CRIMINAL LAW IN THE ROME STATUTE,
www.department-ambos.uni-goettingen.de/data/documents/Veroeffentlichungen/epapers/General
_Principles.pdf.
11
Ibid.
12
“Rome Statute of the International Criminal Court, 1998.” United Nations, United Nations,
legal.un.org/icc/statute/99_corr/cstatute.htm.
Legal Opinion
Rural poverty equals invisibility

“What you don’t see, doesn’t affect you.”

Governments, development agencies, non-governmental
organizations and the private sector have been working for decades
on rural development in developing countries but still rural areas lag
far behind cities and outlying areas in terms of infrastructure,
13
services, social and economic development. We somehow
differentiate our perception of poverty in terms of where this less
fortunate is located, for example those we see on the streets and
those we do not even know experiencing extreme poverty even
though they may have shelter.
In developed countries we worry about the rise of beggars on
the streets, which make us feel uncomfortable as we step around
them to enter our favourite cafe, bank or shop, and sometimes we
offer them a coin or something to eat or drink. But the poor in rural
areas barely affect us. Perhaps subconsciously we think, they are
living on the land, they can produce their own food, whereas seeing
beggars in urban areas surrounded by concrete is perhaps more
14
identifiable as poverty. That is one of our most common
misconceptions of poverty. We see those who are on the streets
more unfortunate than that of those who lived in rural areas. The rural
poor are largely off our radar, even off the radar of many
governments it would appear. They exist, we exist but we seem
unable to bridge the divide effectively.
The irony is that rural poverty increases the vulnerability of
governments to instability, terrorism and economic vulnerability
because poverty can easily be exploited and the poor manipulated.
But if we are seeking solutions to feed a growing world population
projected to reach 9.8 billion people by 2050, the problem is
fundamental to human survival. We help the food producers, the
majority of them in rural areas and smallholders, we help ourselves,
15
we also add to political stability and economic prosperity. We need
not just to confine ourselves of what we see. We should also be
aware of those that we don’t see because somehow, what we don’t
see is the most that affects us unconsciously.

13
Small, Alison. “Why Does Rural Poverty Equal Invisibility?” - Global Issues, 30 Apr. 2018,
www.globalissues.org/news/2018/04/30/24152.
14
Ibid.
15
Ibid.
 Let us not limit our understanding and awareness of just relying
on what we see visually but also those that we don’t see. As a
political animal, we should always be aware and on the watch of what
happens around us, our country and the world.
Case Digest
Grace Poe a Foundling
Poe-Llamanzares vs. COMELEC
Facts:
Mary Grace Natividad S. Poe-Llamanzares was found
abandoned as a newborn infant in the Parish Church of Jaro, Iloilo on
Sept. 3, 1968. After passing the parental care and custody over
petitioner by Edgardo Militar to Emiliano Militar and his wife, she has
been reported and registered as a foundling and issued a Foundling
Certificate and Certificate of Live Birth, thus was given the name,
16
Mary Grace Natividad Contreras Militar.

When the petitioner reached the age of five (5), celebrity

spouses Ronal Allan Kelley (aka Fernando Poe, Jr) and Jesusa
Sonora Poe (aka Susan Roces) filed a petition foe her adoption. The
trial court granted their petition and ordered that her name be
17
changed to Mary Grace Natividad Sonora Poe.

She married Teodoro Misael Daniel V. Llamanzares, a citizen of

both the Philippines and the U.S., in San Juan City and decided to fly
back to the U.S. after their wedding. She became a naturalized
American citizen in 2001. After her father’s death, the petitioner and
her husband decided to move and reside permanently in the
Philippines in 2005 and immediately secured a TIN, then her children
18
followed suit; acquired property where she and her children resided.

In 2006, she took her Oath of Allegiance to the Republic of the

Philippines pursuant to RA No. 9225 or the Citizenship retention and
Re-acquisition Act of 2003; she filed a sworn petition to reacquire
Philippine citizenship together with petitions for derivative citizenship
on behalf of her three children which was granted. She registered as
a voter; secured Philippine passport; appointed and took her oath as
Chairperson of the MTRCB after executing an affidavit of
Renunciation of American citizenship before the Vice Consul of the

16
jhoygdllawjournal, /. “CASE DIGEST – Poe-Llamanzares v COMELEC.” Law Journal, 2 Nov.
2017, jhoygdllawjournal.wordpress.com/2017/09/10/case-digest-poe-llamanzares-v-comelec/.
17
Ibid.
18
Ibid.
USA and was issued a Certificate of Loss of Nationality of the USA in
19
2011.

In 2012, she filed with the COMELEC her Certificate of

Candidacy (COC) for Senator for the 2013 Elections wherein she
answered “6 years and 6 months” to the question “Period of
residence in the Philippines before May 13, 2013.” Petitioner obtained
the highest number of votes and was proclaimed Senator on 16 May
20
2013.

On 15 October 2015, petitioner filed her COC for the

Presidency for the May 2016 Elections. In her COC, the petitioner
declared that she is a natural-born citizen and that her residence in
the Philippines up to the day before 9 May 2016 would be ten (10)
years and eleven (11) months counted from 24 May 2005. The
petitioner attached to her COC an “Affidavit Affirming Renunciation of
U.S.A. Citizenship” subscribed and sworn to before a notary public in
21
Quezon City on 14 October 2015.

Petitions were filed before the COMELEC to deny or cancel her

candidacy on the ground particularly, among others, that she cannot
be considered a natural-born Filipino citizen since she cannot prove
that her biological parents or either of them were Filipinos. The
COMELEC en banc cancelled her candidacy on the ground that she
was in want of citizenship and residence requirements, and that she
22
committed material misrepresentations in her COC.

On certiorari, the Supreme Court reversed the ruling and held

(9-6 votes) that Poe is qualified as a candidate for Presidency. Three
justices, however, abstained to vote on the ​natural-born​ citizenship
23
issue.

Issue:
Whether or not Mary Grace Natividad S. Poe-Llamanzares is a
natural-born Filipino citizen

Ruling:

19
Ibid.
20
jhoygdllawjournal, /. “CASE DIGEST – Poe-Llamanzares v COMELEC.” Law Journal, 2 Nov.
2017, jhoygdllawjournal.wordpress.com/2017/09/10/case-digest-poe-llamanzares-v-comelec/.
21
Ibid.
22
Ibid.
23
Ibid.
 Yes. Mary Grace Natividad S. Poe-Llamanzares may be
considered a natural-born Filipino. It ruled that a foundling is a
natural-born citizen of the Philippines as there is no restrictive
language which would definitely exclude foundlings as they are
already impliedly so recognized. There are also no provisions in the
Constitution with intent or language permitting discrimination against
foundlings as the three Constitutions guarantee the basic right to
24
equal protection of the laws.

Foundlings are citizens under international law as this is

supported by some treaties, adhering to the customary rule to
presume foundlings as having born of the country in which the
25
foundling is found.

24
jhoygdllawjournal, /. “CASE DIGEST – Poe-Llamanzares v COMELEC.” Law Journal, 2 Nov.
2017, jhoygdllawjournal.wordpress.com/2017/09/10/case-digest-poe-llamanzares-v-comelec/.
25
Ibid.
Case Digest
Enhanced Defense Cooperation Agreement into a conclusion
Saguisag vs. Executive Secretary Paquito Ochoa
Facts:
The Enhanced Defense Cooperation Agreement (EDCA) is an
executive agreement that gives US troops, planes and ships
increased rotational presence in Philippines military bases and allows
the US to build facilities to store fuel and equipment there. It was
signed against the backdrop of the Philippines’ maritime dispute with
26
China over the West Philippine Sea.

Petitions for Certiorari were files before the Supreme Court

assailing the constitutionality of the agreement. Herein petitioners
now contend that it should have been concurred by the senate as it is
27
not an executive agreement.

Issue:
Whether or not the EDCA between the Philippines and the US
is constitutional

Ruling:
Yes. The EDCA is an executive agreement and does not need
the Senate’s concurrence. As an executive agreement, it remains
consistent with existing laws and treaties that it purports to
28
implement.
Petitioners contend that the EDCA must be in the form of a
treaty duly concurred by Senate. The President, however, may enter
into an executive agreement on foreign military bases, troops, or
facilities, if (a) it is not the instrument that allows the presence of
foreign military bases, troops, or facilities; or (b) it merely aims to
29
implement an existing law or treaty.
In order to keep the peace in its archipelago and to sustain itself
at the same time against the destructive forces of nature, the
Philippines will need friends. Who they are, and what form the

26
​Filart, Mikee. “Saguisag v. Executive Secretary.” ​Scribd,​ Scribd, 29 Mar. 2016,
www.scribd.com/doc/306279475/Saguisag-v-Executive-Secretary.
27
Ibid.
28
Ibid.
29
Ibid.
friendships will take, are for the President to decide. The only
restriction is what the Constitution itself expressly prohibits.
Summary
Geneva Convention
The Geneva Conventions are international treaties binding on
all States which have accepted them. The Conventions are long and
complicated, but they are essentially a series of 'do's' and 'don'ts' to
apply during conflict to protect vulnerable and defenceless
30
individuals. Their underlying principles can be simply stated.

(a) C
​ onvention (I) for the Amelioration of the Condition of the
Wounded and Sick in Armed Forces in the Field. Geneva,
12 August 1949. Convention (II) for the Amelioration of the
Condition of Wounded, Sick and Shipwrecked Members of
Armed Forces at Sea. Geneva, 12 August 1949.

The first Geneva Convention ("for the Amelioration of the Wounded

and Sick in Armed Forces and Field") and the second Geneva
Convention ("for the Amelioration of the Condition of Wounded,
Sick and Shipwrecked Members of Armed Forces at Sea") are
similar, covering land and sea respectively. They embody the
main idea which led to the founding of the Red Cross: if a
member of the armed forces is wounded or sick, and therefore
in no condition to take an active part in the hostilities, he is no
longer part of the fighting force and becomes a vulnerable
31
person in need of protection and care.

The main points of these two Conventions are: The sick, wounded
and shipwrecked must be cared for adequately. Belligerents
must treat members of the enemy force who are wounded, sick
or shipwrecked as carefully they would their own. All efforts
should be made to collect the dead quickly; to confirm death by
medical examination; to identify bodies and protect them from
robbery. Medical equipment must not be intentionally destroyed
and medical establishments and vehicles must not be attacked,
damaged or prevented from operating even if, for the moment,
32
they do not contain patients.

​ onvention (III) relative to the Treatment of Prisoners of

(b) C
War. Geneva, 12 August 1949.

30
“Geneva Convention.” GENEVA CONVENTION,
www.ppu.org.uk/learn/texts/doc_geneva_con.html.
31
Ibid.
32
Ibid.
The third Geneva Convention ("Relative to the Treatment of Prisoners
of War") covers members of the armed forces who fall into
enemy hands. They are in the power of the enemy State, not of
33
the individuals or troops who have captured them.

Prisoners of war MUST be:

- Treated humanely with respect for their persons and their honour.
- Enabled to inform their next of kin and the Central Prisoners of War
Agency (ICRC, the International Red Cross) of their capture.
- Allowed to correspond regularly with relatives and to receive relief
parcels.
- Allowed to keep their clothes, feeding utensils and personal effects.
- Supplied with adequate food and clothing.
- Provided with quarters not inferior to those of their captor's troops.
- Given the medical care their state of health demands.
- Paid for any work they do.
- Repatriated if certified seriously ill or wounded, (but they must not
resume active military duties afterwards).
34
- Quickly released and repatriated when hostilities cease.

Prisoners of war must NOT be:

-Compelled to give any information other than their name, age, rank
and service number.
- Deprived of money or valuables without a receipt (and these must
be returned at the time of release).
- Given individual privileges other than for reasons of health, sex,
age, military rank or professional qualifications.
- Held in close confinement except for breaches of the law, although
their liberty can be restricted for security reasons.
- Compelled to do military work, nor work which is dangerous,
35
unhealthy or degrading.

​ onvention (IV) relative to the Protection of Civilian

(c) C
Persons in Time of War. Geneva, 12 August 1949.

The Geneva Conventions which were adopted before 1949 were

concerned with combatants only, not with civilians. Some
provisions concerning the protection of populations against the
consequences of war and their protection in occupied territories
are contained in the Regulations concerning the laws and
customs of war on land, annexed to the Hague Conventions of
1899 and 1907. During World War I The Hague provisions
proved to be insufficient in view of the dangers originating from

33
“Geneva Convention.” GENEVA CONVENTION,
www.ppu.org.uk/learn/texts/doc_geneva_con.html.
34
Ibid.
35
Ibid.
 air warfare and of the problems relating to the treatment of
civilians in enemy territory and in occupied territories. The
International Conferences of the Red Cross of the 1920's took
the first steps towards laying down supplementary rules for the
36
protection of civilians in time of war.

The 1929 Diplomatic Conference, which revised the Geneva

Convention on wounded and sick and drew up the Convention
on the treatment of prisoners of war, limited itself to
recommending that "studies should be made with a view to
concluding a convention on the protection of civilians in enemy
territory and in enemy occupied territory." A draft convention
containing 33 articles prepared by the International Committee
of the Red Cross was approved by the International Conference
of the Red Cross in Tokyo in 1934 and is generally referred to
as the "Tokyo Draft". It was to be submitted to a diplomatic
conference planned for 1940, but this was postponed on
account of the war. The events of World War II showed the
disastrous consequences of the absence of a convention for the
37
protection of civilians in wartime.

The Convention adopted in 1949 takes account of the experiences of

World War II. It contains a rather short part concerning the
general protection of populations against certain consequences
of war (Part II), leaving aside the problem of the limitation of the
use of weapons. The great bulk of the Convention (Part III -
Articles 27-141) puts forth the regulations governing the status
and treatment of protected persons; these provisions
distinguish between the situation of foreigners on the territory of
one of the parties to the conflict and that of civilians in occupied
38
territory.

The Convention does not invalidate the provisions of the Hague

Regulations of 1907 on the same subjects but is supplementary
to them.

36
Geneva Convention.” GENEVA CONVENTION,
www.ppu.org.uk/learn/texts/doc_geneva_con.html.
37
Ibid.
38
Ibid.
Reaction paper
Climate Change Treaty of Paris

The Paris Agreement builds upon the Convention and for the
first time brings all nations into a common cause to
undertake ambitious efforts to combat climate change and adapt to its
effects, with enhanced support to assist developing countries to do
39
so. As such, it charts a new course in the global climate effort.

The Paris Agreement central aim is to strengthen the global

response to the threat of climate change by keeping a global
temperature rise this century well below 2 degrees Celsius above
pre-industrial levels and to pursue efforts to limit the temperature
increase even further to 1.5 degrees Celsius. Additionally, the
agreement aims to strengthen the ability of countries to deal with the
impacts of climate change. To reach these ambitious goals,
appropriate financial flows, a new technology framework and an
enhanced capacity building framework will be put in place, thus
supporting action by developing countries and the most vulnerable
countries, in line with their own national objectives. The Agreement
also provides for enhanced transparency of action and support
40
through a more robust transparency framework.

The Paris Agreement was already signed by President Rodrigo

R. Duterte which shows his seriousness in fighting climate change. It
is a step taken to prevent our country from the adverse effect of
global warming. Signing such Paris Agreement reflects the
President’s sincerity in cooperating with the goal of the international
community to address the problem of climate change.

As for my take as to the signing of the Paris Agreement, it is a

way of acknowledging that climate change is a problem that needs to
be addressed by everyone. We all have our global obligation to
41
contribute to solutions to the global climate crisis. Therefore, the
Philippines should never turn its back regarding this matter.

39
“The Paris Agreement.” UNFCCC,
unfccc.int/process-and-meetings/the-paris-agreement/the-paris-agreement.
40
Ibid.
41
Jalandoni, Apples. “Climate Activists Laud Duterte for Signing Paris Agreement.” ABS-CBN
News, 1 Mar. 2017,
news.abs-cbn.com/news/03/02/17/climate-activists-laud-duterte-for-signing-paris-agreement.