six hundredfifty-one (651) out of the nine hundred seven (907) appellants weresaved from thelethal injection. 27. Justice, judges and prosecutors are human beings, hence, proneto error. As such their decisions are bound by their innate human limitations. Consequently, there can be noinfallibility of courts and the High Tribunal. Once judicial error is committed and execution is carried out, there is no reversing the outcome. Death is irreversible. “No judiciary, anywhere in the world,is so robust that it can guarantee that innocentlife not be taken, and there is an alarming body of evidence to indicate that even well-functioning legal systems have sentenced to death men and women who were subsequently proven innocent.”43 28. The revival of the death penalty will create perturbing effect to our Filipino migrant workers who are on death row and communicate a clean message to host countries practicing death penalty. In a country which legalizes death penalty, migrant workers form an exceptionally vulnerable community. Filipino migrant workers sentenced to death will be left with no recourse but to submit to the fate of execution as the Philippine government which is bound to protect them will lessen its moral integrity and effectiveness to appeal for clemency shouldit decideto reinstate the capital punishment. How could you expect a nation to grant the request for clemency of another sovereign having a national policy imposing death penalty? 29. Unprotected as they are, Filipino migrant workers are set to experience discrimination and the perils and uncertainties concomitant with working abroadwill be further amplified once the death penalty is reinstated. 30. In the Middle East, low-income migrant workers havelittle or no access_ to legal aid, and in the vast majority of cases, cannot afford to pay for legal representation or services. The legal systems in the Gulf can be described as "impossible to navigate" for non-Arabic speakers. Local laws are applied to migrants (including the government's interpretation of Sharia law in Saudi Arabia) yet there are no provisions to ensure that migrants can understand the legal system or laws - even in cases where defendants could be given the death sentence. Built upon a system of bias towards nationals, the legal systems in the Gulf countries reviewed in this report are deeply flawed in termsof fair and independenttrials, presumption of innocence, andtheright to question witnesses.44 31. Migrants, mostly Asians and Africans, whoface capital trials in the kingdom, are frequently unable to understand court proceedings in Arabic, are often not represented by a lawyer, and are routinely held for long periods in harsh conditions and forced into false confessions. The numberof migrant workers from poor sending countries killed under the death penalty in Saudi Arabia is disproportionally high in relation to the total number of migrants in the country. The death penalty is applied discriminatively against poor foreign workers.45 Zeid Ra'ad Al Hussein, United Nations High Commissioner for Human Rights. See: http://www. ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=15101 &LangID=Ea (Accessed on 4 November2016) a Migrant Workers and the Death Penalty in Saudi Arabia and Bahrain; See: http://www.bahrainrights. org/en/node/3054, accessed on 12 October 2016. *Tbid. 63