Press conference in The Hague launching the Report. On screen: Maria Kristina Conti discusses the red-tagging, harassment, and threats she faces as legal counsel for some of the purported victims of Duterte's regime in a case before the International Criminal Court.
A disturbing pattern of extrajudicial killings, harassment and systematic human rights violations targeting legal professionals in the Republic of the Philippines has been revealed in a new report, Black Robes, Red Targets (the Report), published by the Caravana Filipina - an international fact-finding mission led by a coalition of ten legal organisations, including the International Bar Association's Human Rights Institute (IBAHRI).
The attacks analysed in the Report took place between 2016 and 2023, in a broader context of repression under the presidency of Rodrigo Duterte and his so-called 'war on drugs.' The Caravana Filipina's focus is on attacks against legal professionals as it builds on a fundamental premise: that justice systems cannot function - and democracies cannot survive - when those who defend the rule of law are themselves at risk.
The report is the culmination of months of desk research and 10 days of intensive fieldwork across the Philippines, collecting testimonies from around 100 individuals. The delegation also engaged with several domestic institutions, including the Supreme Court and the Commission on Human Rights, and various civil society and academic groups. The Report aims to answer a series of pressing questions:
- What is the professional hazard of being a public interest lawyer or an independent judge/prosecutor in the Philippines?
- What has become of the rule of law in the Philippines when lawyers, judges, and prosecutors are being harassed, red-tagged, and killed for fulfilling their professional duties?
- What responsibilities does the Philippine State bear for these human rights violations?
- Why did none of the cases of killed legal professionals proceed to trial?
- What are the avenues towards redress for victims and to re-establish confidence in institutions?
Read a summary of the findings and recommendations in the press conference statement.
Read the Report.
Watch the 20-minute documentary by Jacco Groen.
Watch the presentation of the Report (part 1), which includes IBAHRI lawyer Eleonora Scala comments.
Watch the presentation of the Report (part 2) with representatives of Caravana Filipina.
The Caravana Filipina investigation revealed that legal professionals in the Philippines continue to be attacked solely for carrying out their professional duties, upholding the rule of law and speaking truth to power. The Report underscores that these attacks were not isolated incidents, but form part of a targeted strategy to silence human rights defenders and stifle dissent in the Philippines. The Report details a four-phase system of oppression targeting legal professionals working on public-interest cases. This includes surveillance and intimidation, red tagging (labelling legal professionals as communists or enemies of the state), lawfare tactics (the weaponisation of law to issue arbitrary search warrants, plant evidence and arrest lawyers on false charges) and ultimately extrajudicial killings (targeted assassinations, mostly carried out in daylight by two assailants on a motorcycle with their faces covered).
The government's failure to protect legal professionals from intimidation, harassment and violence puts the Philippines in breach of its obligations to uphold the independence of the judiciary and the legal profession, as guaranteed by the country's Constitution and the United Nations Basic Principles on the Role of Lawyers . This failure poses a serious threat to access to justice in the country. Even more gravely, credible evidence gathered indicates that the Philippine State is also in violation of its obligation to protect and respect the right to life of legal professionals, as enshrined in the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights . The State bears responsibility for the physical attacks and extrajudicial killings of legal professionals - whether through direct involvement or acquiescence.
Further documented in the Report are the structural flaws in the investigation system, which are systematically exploited by the authorities to foster a pervasive culture of impunity. This is reflected in a consistent pattern of inadequate investigations into the killings of legal professionals, with all but one of the cases analysed by the Caravana Filipina prematurely declared "cold cases".
The Report makes several recommendations for the Philippines government to ensure justice and accountability for the victims of the abuses, including:
- establishing an independent and impartial investigative body, with specific institutional safeguards, to thoroughly examine all extrajudicial killings, threats and other forms of harassment against legal professionals in the Philippines;
- developing reparations policies for victims of human rights violations by the Philippines government;
- cooperating fully with the International Criminal Court (ICC) in the context of the ongoing proceedings against former President Rodrigo Duterte; and
- strengthening cooperation with UN human rights mechanisms , including through monitoring and technical assistance.
To address the root causes of impunity, the Report calls for reforms such as:
- strengthening judicial independence by improving mechanisms for the appointment of judges and prosecutors, and creating a special protection protocol for those facing threats;
- ratifying the 2025 Council of Europe Convention for the Protection of the Profession of Lawye r;
- investigating and dismantling of government bodies reported to be involved in human rights violations like the National Task Force to End Local Communist Armed Conflict (NTF-ELCAC) and its agents and proxies;
- adopting legislation to define and criminalise red-tagging;
- reforming legislation to end the weaponisation of counter-terrorism laws to criminalise and obstruct the legitimate activities of human rights defenders and aid organisations;
- reforming the Commission on Human Rights of the Philippines (CHR) to strengthen its role as the country's human rights watchdog; and
- reforming legislation to ensure that all investigations into suspicious deaths meet the international standards outlined in the Minnesota Protocol .
The Report's authors also emphasised the role of the international community in leveraging legal and diplomatic tools to pressure the Philippine government to advance accountability and strengthen institutions. They stressed that 'human rights must be a non-negotiable red line in all bilateral and multilateral relations.' Trade deals and other financial agreements should be conditional on the Philippine government's commitment to deliver justice and accountability.
Launched on 4 June 2025 in the Hague, the report Black Robes, Red Targets not only sheds light on the repression faced by legal professionals in the Philippines but also celebrates their resilience and unwavering commitment to justice despite the dangers involved.
In their closing statement, the Report's authors stressed: 'With the trial of former President Duterte underway at the ICC, we have a vital opportunity to serve justice for the victims. States must build on this momentum by actively engaging with the government of the Philippines to strengthen accountability mechanisms, not only internationally but crucially at the domestic level as well. The time for statements of concern has long passed. What is needed now is sustained, coordinated action.'
