find the AFP institutionally complicit. But it was cited for its lackadaisical attitude towards reports on the involvement of individuals or groups associated with the AFP in the EJKs of activists under Oplan Bantay Laya.110 Similarly, Philip Alston, then UN Special Rapporteur on Extrajudicial Killings, reported in 2008 at the conclusion of his mission that the AFP, sometimes conniving with paramilitaries, carried out a significant number of EJKs against journalists and political dissenters.111 To that extent, in 2012, the UNHRC expressed its concern about unabated EJKs and enforced disappearances, and what it perceived as poor results of investigations and the lack of prosecution of culprits, including the slow progress in the prosecution of the 2009 Ampatuan massacre.112 110. However, the State must also be commended for having positively responded to certain articulated concerns raised by parties. For one, it created HR offices within the police and the AFP, such as under the Internal Peace and Security Plan of the AFP.113 This was a move reported by the Philippines to the Human Rights Council during the second cycle of the Universal Periodic Review, a mechanism established in accordance with Human Rights Council resolution 5/1 of 18 June 2007, during its thirteenth session in 2012.114 111. The AFP’s Internal Peace and Security Plan textually provides that members of the security forces are to be trained regularly on international HR law and international humanitarian law.115 The mere creation of institutional HR mechanisms, however, does not, by itself, fully foster a culture of HR within the AFP. The public deservingly expects to see further steps from the AFP toward cleansing itself of rogue elements who deviate from its prime duty as defender of the people and who contribute to its negative perception. 112. In 2012, the State’s peers in the UN commended the Philippines for stepping up efforts to improve its HR record and for providing enhanced access to justice in general. But they also expressed concern about impunity in HR violations committed by security forces,116 noting the existence of institutional barriers to fighting impunity.117 113. An international fact-finding mission report claims that the Human Rights Officers of the AFP which the mission interviewed revealed that no member of the armed forces had ever been convicted for a HR violation, including in cases of crimes such as torture or EJK. The Mission delegates were told of a couple of instances where armed forces personnel had been charged. 110 Melo Commission, The Melo Commission Report, February 2007, available at http://www.humanrights.asia/resources/ journals-magazines/article2/0601/appendix-ii-the-melo-commission-report. 111 Philip Alston, Report of the Special Rapporteur on extrajudicial, summary or arbitrary executions: Mission to Philippines A/ HRC/8/3/Add.2 16, April 2008. 112 UN Human Rights Committee, Concluding Observations on the Philippines, UN Doc CCPR/C/PHL/CO/4, paras. 14-16. 113 Human Rights Council, Report of the Working Group on the Universal Periodic Review: Philippines, A/HRC/21/12, 9 July 2012, para. 24, at 5. 114 Id., para. 1, at 5. 115 Id., para 24, at 5. 116 Human Rights Council, Report of the Working Group on the Universal Periodic Review: Philippines, A/HRC/21/12, 9 July 2012, paras. 51, 57, 63, 116, at 8-9, 14. 117 Id. 26