by the PAO is sufficient to provide access to justice for poorer citizens in the Philippines. The average caseload of a PAO lawyer is 452 cases per year, a quantity which is likely to cause the quality of legal services to suffer.72 The categories of cases a PAO lawyer is qualified to act on encompasses almost all areas of law, covering ‘criminal, civil, labor, administrative and other quasi-judicial cases’.73 This broad subject matter focus also brings into question the quality of legal services provided, requiring lawyers to deliver advice to and represent clients facing a myriad of legal problems in an environment which requires the disposition of a number of cases per day. This review takes the view that encouraging affected communities to pursue litigation is not an efficient mechanism to provide fairer outcomes in dealing with eviction and resettlement disputes. Cases involving government decisions to evict urban poor citizens or relating to disputes over the delivery of housing-related services are typically administrative in nature and would be more effectively handled in a quasi-judicial forum. The Government should consider law reform measures which encourage these housing and eviction-related disputes to be heard by a single, administrative body to enhance access to justice for the urban poor. To properly comply with standards 2.10 and 3.9 on legal aid and remedies, a comprehensive and accessible appeals framework should be implemented to make remedies available to those affected by violations of the UDHA. This should identify a single and independent administrative complaint body to hear appeals against all decisions of government made or authorised under the UDHA and its IRRs. Reducing the number of government entities that are capable of undertaking evictions and resettlement, or consolidating all housing-related functions into a single agency, would also support greater dispute resolution efficiency in the housing sector and should be considered as a priority for government. Importantly, the empowerment of an independent complaint body is also consistent with the 1995 recommendations of the CESCR and would therefore promote compliance with the Philippines’ international obligations under the International Covenant on Economic, Social and Cultural Rights. 5.4 Resettlement Conditions For evictions undertaken otherwise than by court order, section 28(c)(8) of the UDHA clearly stipulates that ‘adequate relocation, whether temporary or permanent’ must be provided to those subject to eviction and demolition. Whether temporary relocation will satisfy the requirements of international human rights law is uncertain. There is no specification in the UDHA as to when temporary relocation will be sufficient or under what circumstances it will be permitted as an alternative to permanent relocation. Section 1(n) of the IRRs notes that ‘[s]hould a permanent site not be determined within one (1) year, the temporary relocation becomes a socialized housing area’. The application of this provision would be problematic in situations where the host local government and community of the temporary resettlement were under the initial 72 73 For further analysis, see: American Bar Association, Access to Justice Assessment for Philippines: Mindanao, 2012, p. 29. Republic Act 9406, s. 2. 40  Human Rights in the Rubble