subordinate local officials must be filed with the relevant LGU executive. Complaints against national agencies may be filed with either the Office of the President or Office of the Ombudsman. The IRRs further suggest that aggrieved parties can complain to the Commission on Human Rights, the Presidential Commission for the Urban Poor, the Public Attorney’s Office of the Department of Justice or in all instances file a complaint directly with a court of competent jurisdiction. In practice, the dispute resolution body authorised to hear the complaint will depend on the nature of the dispute and the particular entity that is responsible for the adverse decision. The multitude of actors involved in the resettlement process, and various government agencies that undertake evictions on a regular basis, thus produce the numerous appeals channels in the housing sector. The sheer number of potential avenues for dispute resolution is liable to confuse potential complainants, leaving affected persons uncertain as to which mechanism to access to obtain recourse. Administrative remedies available to aggrieved parties are typically enforced against offending officials themselves, rather than agencies, for breaches of the UDHA or the IRRs. For example, decisions made by LGU executives that are deemed incompatible with the UDHA or IRRs shall be subject to penalties in accordance with section 61 of the Local Government Code. The Local Government Code specifies that penalties against offending officials include discipline, suspension or removal from office.68 No impersonal administrative remedies against offending LGUs, such as restitution, setting aside of the original decision or compensation, are contemplated by the Local Government Code. This leaves complainants without recourse to satisfactory administrative remedies against decisions of local government. Many other complaint mechanisms, such as the investigative functions of the Commission on Human Rights, lack the power to enforce their decisions against offending agencies and officials. Remedies may be sought by commencing formal legal proceedings at a competent court, as is also mentioned in the IRRs. However, this process is generally inaccessible to those affected by adverse housing decisions. Retaining counsel and pursuing litigation against government requires considerable expense and is almost always out of reach of those who suffer the effects of breaches of the UDHA and its IRRs. There is some provision in the IRRs for legal aid available to those who cannot afford legal representation when they are facing an eviction order or other dispute arising from the UDHA. Section 8 of the IRRs notes that ‘[a]n aggrieved urban poor organization or person may seek the legal assistance of the Public Attorney's Office of the Department of Justice for violations hereof’. The Public Attorney’s Office (PAO) is authorised by law to provide free legal assistance to ‘indigent’ clients.69 Access to legal aid is both means and merit tested, with potential awardees being subject to a monthly income threshold for Metro Manila of PHP14,000.70 Independently of the Philippine legal framework, the National Committee on Legal Aid of the Integrated Bar of the Philippines (IBP) establishes a mechanism for means and merit tested legal aid to be provided in the form of pro bono assistance and representation.71 There are questions as to whether in practice the purportedly comprehensive system of legal aid provided 68 ss. 60 and 63. See: Republic Act 9406, s. 2. 70 Public Attorney’s Office, Memorandum Circular No 18 of 2002, s. 1. 71 See: Integrated Bar of the Philippines, Guidelines on Legal Aid, 1974, art. 8. 69 39