DESK REVIEW ON POPULATIONS AT RISK OF STATELESSNESS that “[a]s a matter of law, foundlings are as a class, natural-born citizens,”49 and the Government of the Philippines has pledged to adopt “legislation to implement the ruling from the Supreme Court, through which foundlings are presumed to be natural born citizens” and “a domestic law on the citizenship of foundlings” as part of its strategy.50 As part of the NAP, the Government of the Philippines has included action points to ensure that “No Child is Born Stateless”; and “Ensure Birth Registration for the Prevention of Statelessness.”51 In addition to the above listed populations, over 100 applications have been made by persons of Japanese Descent (PJD) to the statelessness status determination procedures in the Philippines.52 Six cases so far have been recognized as stateless by the DOJ of the Philippines through the process. The Philippine Nikkeijin Legal Support Center (PNLSC) has documented 3,836 PJD in the Philippines and considers 910 of those cases to be at risk of statelessness in the Philippines as of 5 May 2020.53 PNLSC also believes there may be more who have not been reached, and emphasizes that because the average age of the Philippine Nikkeijin community members is 81, the situation is urgent. Around two million Filipinos seek employment opportunities overseas annually.54 Many are temporary or irregular migrants, and this may include children of Philippine descent in migratory settings who are at risk of statelessness. The risks may be particularly high in Sabah, Middle East, and Central and East Asia, where registration of birth is complicated due to access issues as well as gender, race, and other forms of discrimination in civil registration laws, and the risks of being undocumented. Particular concern has been raised about an estimated 55,000 to 97,000 persons of Philippine descent in Sabah;55 as well as Mary Grace Natividad S. Poe-Llamanzares v. COMELEC, G.R. Nos. 221697 & 221698-700, 8 March 2016. (The Court based its decision on deliberations of the framers of the 1935 Constitution that specifically discussed foundlings, and the generally accepted principle of international law ‘to presume foundlings as having been born of nationals of the country in which the foundling is found.’). 49 See: the Philippines Joint Strategy, Section 2.2 “Promoting law reform, and its implementation, to ensure safeguards in nationality laws to prevent statelessness amongst children”; available at: https://www.unhcr.org/ibelong/the-philippines-jointstrategy/. 50 Government of the Republic of the Philippines, National Action Plan on the Elimination of Statelessness by 2024, Action Point 2: “No Child is Born Stateless”; and Action Point 5: “Ensure Birth Registration for the Prevention of Statelessness.” 51 Persons of Japanese Descent may be orphans left behind by parents who died or were returned to Japan or they may have remained with Filipino mothers and may have hidden their identity for fear of discrimination. 108 cases are reported to have approached the DOJ-RSPPU. 52 Figures are according to the numbers collected by the Philippine Nikkeijin Legal Support Center in work commissioned by the Ministry of Foreign Affairs of Japan. 53 Philippine Development Plan 2017-2022, available at: http://pdp.neda.gov.ph/wp-content/uploads/2021/02/PrepublicationUpdated-PDP-2017-2022-as-of-Feb-10.pdf (updated 10 February 2021). 54 These numbers come from the Immigration Office in Malaysia in 2018, documented as persons who continue to annually renew the documentation issued to former Filipino refugees, but more up to date and accurate statistics are needed, and these figures may also include individuals who are not at risk of statelessness. 55 UNHCR / April 2021 21