43. The allegation that schools are teaching matters outside of the DepEd approved curriculum and operating as fronts of the CPP-NPA-NDF are very serious. If proven, their closure would be warranted. However, the investigation must be comprehensive and independent and the evidence supporting closure must be clear and convincing. 44. The strong bias of this Commission, recognizing the basic human right to education, is towards the operation of alternative schools, especially in hardly reached areas. 45. The unilateral issuance of a Notice of Non-Renewal of Permit that led to the temporary closure of STTICLC schools could have fallen short of prescribed HR standards. IPs are guaranteed the fundamental freedoms recognized under international HR law, and among these fundamental rights is the right to due process.50 46. Based on the testimonies of DepEd representatives, the State did not provide the STTICLC officials the opportunity to contest the intended closure of their schools. It must be stressed that the IPs, particularly children, including those living outside their communities, have a right to education in their own culture.51 The temporary closure of the subject facilities, no matter how brief, violated this right. 47. The Constitution guarantees the right of all citizens to quality education at all levels and commands the government to take appropriate steps to make such education accessible to all.52 The State shall establish, maintain and support a complete, adequate and integrated system of education relevant to the needs of the people and society.53 As regards IPs, the State encourages non-formal, informal and indigenous learning systems, as well as self-learning, independent and out-of-school study programs, particularly those that respond to community needs.54 Employment of Paramilitaries and Militias 48. As far back as Martial Law under Marcos, the AFP has been persistently linked to private militias and paramilitary groups.55 49. Alamara and paramilitary abuses figure prominently in the complex discourse of issues concerning the Lumad of Mindanao, particularly those who encamped in the UCCP Compound in Haran, Davao. Alamara was regarded by Datu Bontolan and other Lumad leaders as a paramilitary group organized by the AFP. 50. They described harassment in the hands of the Alamara. They identified it 50 Article 1, UNDRIP. 51 Article 14, UNDRIP. 52 Id., Section 1, Article XIV 53 Id., Section 2 (1), Article XIV. 54 Id., Section 2 (4), Article XIV. 55 United States Department of State Bureau of Democracy, Human Rights and Labor, Philippines 2013 Human Rights Report in Country Reports on Human Rights Practices for 2013, at 10. 13

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