10 Addressing Inequality During the Pandemic measure up to the international standards set by the United Nations in the Minnesota Protocol.25 40 The Minnesota Protocol outlines States’ legal obligations as well as common standards and guidelines relating to the investigation of potentially unlawful deaths, which may have been caused by any of the following: a Acts or omissions of the State, its organs or agents, or may otherwise be attributable to the State, in violation of its duty to respect the right to life; b Deaths in custody or detention; c Where a State fails to exercise due diligence to protect an individual from foreseeable external threats or violence by non-State actors such as vigilante-style killings; d Failure of the State to investigate any suspicious death, even where it is not alleged or suspected that the State caused the death or unlawfully failed to prevent it.26 41 Due to COVID-19 restrictions, walk-in clients of the CHR CAR decreased. Other legal services were sought and provided through electronic means such as mobile text messaging, phone calls, e-mails, and through the office social media accounts. Regular cases were received through walk-in clients, referrals and motu proprio investigations. These motu proprio investigation cases were gathered through news articles, particularly those uploaded in social media. 27 42 One non-drug related EJK case involves the killing of a Deputy City Prosecutor of llagan, Isabela. The victim sustained several bullet wounds on his body. He was killed by ridingin-tandem gunmen who waited for him near his residence. Police investigators are looking at the angle that the killing was likely job-related.28 43 The alleged three drug related killings docketed in the CHR CAR are drug surrenders or those implicated in a drug case where a drug substance was found in their body. As to circumstances of commission, the victims’ dead bodies were dumped in a secluded area where the victims might be discovered only by chance. Also, the victims went missing for one to several days and then were found dead. One of the victims was shot to death and the other two suffered puncture wounds to their bodies and strangulation marks to their neck similar to the previous drug related killings investigated by this office. In all these cases, it was reported that the victims did not die in the place where they were found but someplace else since the amount of blood found at the scene did not match the injuries sustained by the victims, nor were there any signs of struggle in the place where the bodies were found.29 25 Commission on Human Rights. (2021, September). REPORT ON INVESTIGATIONS RELATED TO THE ANTIILLEGAL DRUG CAMPAIGN (with Analysis on Regions NCR, III, and IV-A). 26 Commission on Human Rights. (2021, September). REPORT ON INVESTIGATIONS RELATED TO THE ANTIILLEGAL DRUG CAMPAIGN (with Analysis on Regions NCR, III, and IV-A). 27 Commission on Human Rights Cordillera Administrative Region. (2021, August). HUMAN RIGHTS SITUATION REPORT ON THE MONITORING OF COVID-19 VACCINATION PROGRAM CORDILLERA ADMINISTRATIVE REGION. 28 Commission on Human Rights Cordillera Administrative Region. (2021, August). HUMAN RIGHTS SITUATION REPORT ON THE MONITORING OF COVID-19 VACCINATION PROGRAM CORDILLERA ADMINISTRATIVE REGION. 29 Commission on Human Rights Cordillera Administrative Region. (2021, August). HUMAN RIGHTS SITUATION REPORT ON THE MONITORING OF COVID-19 VACCINATION PROGRAM CORDILLERA ADMINISTRATIVE REGION.