The reference within Article 6 to “the most serious crimes” is fundamental. It has been widely considered by domestic courts and international bodies. As a party to the ICCPR, the Philippines is obliged to perform its treaty obligations in good faith26 consistent with the time-honored principle of pacta sunt servanda. It must interpret treaties “in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in the light of its object and purpose.”27 The UN HRC has considered the content of Article 6. The Committee is responsible for oversight of the ICCPR and may receive Communications from individuals seeking to lodge complaints under the Optional Protocols to the Covenant. The Views of the Committee on the interpretation of the Covenant are considered highly persuasive and authoritative. General Comment No. 6 of the HRC elaborated on death penalty and the right to life. It notes that: 6. While it follows from article 6 (2) to (6) that State parties are not obliged to abolish the death penalty totally they are obliged to limit its use and, in particular, to abolish it for the other than the “most serious crimes”. Accordingly, they ought to consider reviewing their criminal laws in this light, and in any event, are obliged to restrict the application of the death penalty to the “most serious crimes” … 7. The Committee is of the opinion that the expression “most serious crimes” must be read restrictively to mean that the death penalty should 28 be a quite exceptional measure. It is clear beyond doubt that Article 6 of the ICCPR, as interpreted by the HRC requires that the death penalty may only be imposed with respect to the most serious crimes. The work of the HRC also establishes beyond doubt that property offences, crimes against the person falling short of murder, financial crimes, pornography and narcotics offences do not constitute “a most serious crime.” In the view of the HRC in Kennedy v. Trinidad & Tobago, a “most serious crime” is one which carries fatal or a similarly grave consequence.29 In its Concluding Observations for Kuwait (UN Doc CCPR/C/KWT/CO/2 (18 November 2011)) the Committee expressed the firm view that drug-related offences were not “most serious” within the meaning of Article 6.30 Similarly, in its Concluding 26 VCLT, art. 26. VCLT, art. 31 (1). 28 UN Human Rights Committee, General Comment No. 6: Article 6 (Right to Life) (Apr. 30, 1982), available at http://www.refworld.org/docid/45388400a.html (last accessed Mar. 03, 2017) [hereinafter HRC GC No. 6], ¶ 6, 7. 29 UN Human Rights Committee, Kennedy v. Trinidad and Tobago, Merits, Communication No. 845/1998, U.N. Doc. CCPR/C/74/D/845/1998 (Mar. 26, 2002). 30 UN Human Rights Committee, Consideration of reports submitted by States parties under article 40 of the Covenant, U.N. Doc. CCPR/C/KWT/CO/2 (Nov. 18, 2011). 27 Page 11 of 23