Protection of human right to life as international customary law. With regard to human rights principles which are of international customary nature, in a long line of cases, the Philippine Supreme Court has consistently applied the same as valid and binding under local law. In one of the most recent explanations of the principle, in Poe-Llamanzares v. Elamparo, the Philippine Supreme Court held that generally accepted principles of international law include international custom as evidence of a general practice accepted as law, and general principles of law recognized by civilized nations. The term "general principles of law recognized by civilized nations" are principles "established by a process of reasoning" or judicial logic, based on principles which are "basic to legal systems generally.”62 Examples are "general principles of equity, i.e., the general principles of fairness and justice," and the "general principle against discrimination" which is embodied in the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, the International Convention on the Elimination of All Forms of Racial Discrimination, the Convention Against Discrimination in Education, the C ILO Convention No. 111 Concerning Discrimination in Respect of Employment and Occupation. The Court declared with definitiveness that these are the same core principles which underlie the Philippine Constitution itself, as embodied in the due process and equal protection clauses of the Bill of Rights.63 In Philippine jurisprudence, the right to life has been explained as forming part of international customary law. These have been included in cases on arbitrary deprivation of life, the writ of amparo, and other protections of the right. In cases bearing on the right to life, Razon v. Tagitis applied the International Convention for the Protection of All Persons from Enforced Disappearance even though the Philippines is not a party to the treaty. The Court declared that the proscription against enforced disappearances, relating as it is to the right to life, is part of the corpus of this general principle of international law as it is a principle of international customary law.64 On the whole, under Philippine jurisprudence, the protection for the right to life is part of customary law, even absent a treaty or domestic law operationalizing the same in domestic law. Treaties are generally regarded are self-executing—requiring no further action for their validity within Philippine jurisdiction.65 In very exceptional cases, it is however possible that the treaty itself may provide for its application through a legislative or executive 62 Poe-Llamanzares v. Elamparo, G.R. No. 221697 (Mar. 08, 2016). Id. 64 Razon, Jr. v. Tagitis, 621 Phil. 536, 600 (2009) citing Pharmaceutical and Health Care Philippines v. Duque III, 561 Phil. 386, 398 (2007). 65 MERLIN M. MAGALLONA, A PRIMER IN INTERNATIONAL LAW IN RELATION TO PHILIPPINE LAW 49 (1997). 63 Page 20 of 23