; what constitutes immediate and effective investigation . (6) In 2022, the International Trade Union Confederation (ITUC) listed the Philippines as one of the 10 worst countries in the world for working people for the sixth consecutive year. In its 2022 report, the ITUC stated: Workers and their representatives in the Philippines remained particularly vulnerable to violent attacks, intimidation and arbitrary arrests. Trade unionists, maliciously red-tagged by President Duterte, remained under immediate threat from the police and the army, which conducted targeted raids against them. Over 50 trade unionists have been killed since President Duterte came to power in 2016 . (7) In the first six months of the Marcos administration alone, the Alliance for Advancement of People’s Rights (Karapatan) has documented 17 extrajudicial killings, 165 illegal arrests, 9,159 forced evacuations, and 357,726 cases of harassment and intimidation. (8) In 2021, the international NGO Global Witness declared the Philippines to be the deadliest country in Asia for environmental activists for the ninth consecutive year. Since President Duterte took office in 2016, 30 environmentalists, 54 indigenous people, and 207 farmers and peasants have been extrajudicially killed. Included in the targeting of environmental activists during this timeframe, was United States citizen, Brandon Lee, who was subjected to an assassination attempt on August 6, 2019. Brandon Lee has been subjected to repeated threats and harassment by the Philippine military due to his advocacy relating to the land and rights of indigenous people in Ifugao province and the surrounding Cordillera region of the Philippines. While Brandon Lee survived the attack, he has been left paralyzed and his assailants have not been brought to justice. (9) Philippine State actors have targeted lawyers, judges, and politicians for repression. According to the National Union of Peoples’ Lawyers, 133 Filipino lawyers have been murdered over the past 40 years, with 59 being murdered during