58. Ten days later, or on 25 July 1987, President Aquino issued Executive Order 264, creating the Citizen Armed Force Geographical Units (CAFGU).59 Under the EO, the CAFGU was to be trained, armed, and placed under the command and control of the AFP,60 to assist it in confronting all types of threats to national security,61 including the mounting insurgency. 59. In the wake of Congress’ act of cutting the budget for the military and the CAFGU program, the DND, in 1989, created the Special CAFGU Active Auxiliary (SCAA). The SCAAs are similar to CAAs in that they were subject to military discipline and the Articles of War, but differed in the primary function of protecting the property and interests of private corporations, business entities, or Local Government Units (LGUs) from the threats posed by criminality and insurgency in their areas of operation.62 The allowances and salaries of SCAA are shouldered by the private corporations, businesses, or LGUs that call for its activation, instead of by the AFP.63 60. The institutionalization of SCAAs upset HR advocates, as can be gleaned from the latter’s submissions and reports to HR bodies. With SCAAs not totally under State control, being paid for by private interests, there was no guarantee that they would not act against public interest. SCAAs were also criticized for legitimizing the employment of private armies which are proscribed by the 1987 Constitution. 61. In 1991, Congress passed RA 7077, also known as the AFP Reservist Act of 1991, which constituted the CAFGU as an integral part of the AFP reserve force. Unlike the CHDF of the Marcos era, the CAFGU is, by law, not a paramilitary unit and is convened only for purposes of counterinsurgency. It is integrated into the military chain of command and is subject to all applicable military laws, rules, and regulations. There are also welldocumented reports of HR violations committed by the CAFGU. 62. The Local Government Code of 1991 affirmed the creation of the Civilian Volunteer Organizations (CVOs), which were first institutionalized as Civilian Volunteer Self-Defense Organizations by Executive Order No. 309, s. of 1987. Called barangay tanod, they do not have legal authority to carry guns64 and should in fact be unarmed. 63. In 2006, President Macapagal-Arroyo’s Executive Order 546 allowed local officials to employ members of the CAFGU and CVOs to purportedly address insurgency. Unarmed under the Local Government Code, CVOs were converted into armed paramilitaries. EO 546 also directed the PNP to 59 Section 5, Executive Order No. 264. 60 Id. 61 Id. 62 Report on the visit to the Philippines by two members of the Working Group on Enforced or Involuntary Disappearances, E/CN.4/1991/20 + Add.1, E/CN.4/1991/20/Add.l 10 January 1991, at https://documents-dds-ny.un.org/doc/UNDOC/GEN/ G91/100/47/PDF/G9110047.pdf?OpenElement. 63 Id. 64 Under the Local Government Code of 1991, only the Punong Barangay, among barangay officials, has express legal authority to carry firearms as provided in Sec. 389. 15