A/HRC/19/75 themselves to claim their rights, they are often treated as criminals, arbitrarily arrested or detained, or become the victims of torture or summary executions by the State or private police forces.48 In 2007, the Special Representative of the Secretary-General on human rights defenders concluded that peasant group leaders were often criminalized, and that the second most vulnerable group when it came to the danger of being killed for their activities in the defence of human rights were defenders working on land rights and natural resources (A/HRC/4/37, paras. 45–47). In the Philippines, for example, three peasant leaders were murdered between November 2008 and June 2009: Vicente Paglinawan, Vice President of the National Coordination of peasant groups for the island of Mindanao; Eliezer Billanes, secretary-general of a peasants’ union; and Renato Penas, Vice President of the National Coalition of Peasant Organizations.49 On 17 April each year, La Via Campesina commemorates the 1996 massacre of 19 landless peasants at Eldorado do Carajas (Brazil). IV. Protection of the rights of peasants and other people working in rural areas under international human rights law 43. The rights of peasants and other people working in rural areas are not subject to any specific protection under international law. Like all human beings, however, these people benefit from the protection of the international human rights instruments. 50 In particular, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights offer significant protection to the rights of peasants and other people working in rural areas. Women living in rural areas and indigenous people also benefit from the protection granted by the Convention on the Elimination of All Forms of Discrimination against Women and the United Nations Declaration on the Rights of Indigenous Peoples. A. International Covenant on Economic, Social and Cultural Rights 44. Articles 11, 12 and 13 of the International Covenant on Economic, Social and Cultural Rights protecting (a) the right to food, (b) the right to adequate housing, (c) the right to health, (d) the rights to water and sanitation and (e) the right to education are the most relevant with regard to the protection they offer for the rights of peasants and other people working in rural areas. 1. Right to food 45. The right to food was proclaimed in article 25 of the Universal Declaration of Human Rights and enshrined in article 11 of the Covenant. It has been interpreted as the right of all people to “be able to feed themselves, by their own means, with dignity”. The Committee on Economic, Social and Cultural Rights, in its general comment No. 12 (1999), stated that the right to adequate food is realized when every man, woman and child, alone or in community with others, has physical and economic access at all times to adequate food or means for its procurement (para. 6). 48 49 50 La Via Campesina, Annual Report: Violations of Peasants’ Human Rights, 2006. PAKISAMA statement on the assassination of Renato Penas. Available from http://focusweb.org/philippines/content/view/301/4/. See Christophe Golay, The Rights of Peasants, CETIM, 2009 (available from http://cetim.ch/en/documents/report_5.pdf); and C. Golay, “Towards a Convention on the Rights of Peasants” in A. Paasch and S. Murphy, The Global Food Challenge. Towards a Human Rights Approach to Trade and Investment Policies, 2009, pp. 102–111. 13