REPORT ON INVESTIGATED KILLINGS IN RELATION TO THE ANTI-ILLEGAL DRUG CAMPAIGN Nevertheless, in cases of buy-bust operations investigated by the CHR, where police operatives were at a minimum of three, 85% (329 incidents) of them resulted in the death of lone victims. The disproportion in numbers of operatives as to the resulting deaths of mostly lone victims are compounded by the fact that the operatives are trained individuals in firearms handling, arrest techniques, hand-to-hand combat, and self-defense,13 with government-issued and highly firearms. The Revised Philippine National Police Operational Procedures dated December 201314 (Revised PNP-POP Handbook) prescribes only the use of necessary and reasonable force to subdue resistance put up by an aggressor.15 The Revised PNP-POP Handbook provides that the necessity and reasonableness of the force employed will "depend upon the number of aggressors, nature and characteristic of the weapon used, physical condition, size, and other circumstances to include the place and occasion of the assault. The police officer is given the sound discretion to consider these factors in employing reasonable force."16 It should be noted that in its September 2021 Revised Operational Procedures (Revised PNP-POP Manual), the PNP expressly prohibits the use of excessive force during confrontation with armed offenders. It requires that the sufficiency of the force employed by the police must be able to justify self-defense, defense of relative, defense of stranger or fulfillment of duty based on the elements laid down by law and jurisprudence.17 It also defines neutralization as "a police intervention in strict accord with the principle of proportionality on the use of force to contain and stop unlawful aggression such as arrest, capture, surrender, or other acts to subdue the suspect."18 The Revised PNP-POP Manual also enumerates “Three Approaches on The Use of Force Continuum.” It stated that "Lethal force will only be employed when all other approaches [non-lethal and less lethal] have been exhausted and found to be insufficient to thwart the life-threatening actions or omissions posed by armed suspect or law offender." Under the Lethal Approach when a suspect is armed and dangerous and there is an intention to inflict severe injury or death to a police officer, the latter is authorized to "use conventional weapons to prevent or repel the unlawful aggression and immobilize the suspect," but must "as much as possible, avoid hitting the head or other vital parts of the body.”19 In addition, the UN Code of Conduct for Law Enforcement Officials, cited in some PNP manuals, substantially provides that "law enforcement officials may use force only when strictly necessary and to the extent required for the performance of their duty." The Code of Conduct stressed that "while it implies that law enforcement officials may be authorized to use force as is reasonably necessary under the circumstances for the prevention of crime or in effecting or assisting in the lawful arrest of offenders or suspected offenders, no force going beyond that may be used."20 (emphasis supplied) 13 PNP Standard Training Package for Field Training Program. 14 Philippine National Police Handbook, December 2013, PNPM-DO-DS-3-2-13. 15 Revised PNP-POP Handbook (December 2013), Rule 7.5. 16 Revised PNP-POP Handbook (December 2013), Rule 7.6. These factors are reiterated in Section 2.8 of the September 2021 Revised PNP Operational Procedures (PNP Manual PNPM-DO-D-0-2-13-21). 17 Revised PNP Operational Procedures Manual (September 2021), Section 2-4, Rule 2.8. 18 Revised PNP Operational Procedures Manual (September 2021), Glossary of Terms. 19 Revised PNP Operational Procedures Manual (September 2021), Section 2-4, Rule 2.9. See Table 1.3 on Lethal Approach. 20 UN Code of Conduct for Law Enforcement Officials (December 1979), Art. 3. 12