8 Righting Wrongs: Criminal Law Provisions in the Philippines related to National Security and their Impact on Human Rights Defenders aspect of their work that may impede the realization of human rights,23 and to make complaints about official policies and acts relating to human rights and to have such complaints reviewed.24 The Office of the United Nations High Commissioner for Human Rights (OHCHR) describes human rights defenders, as any group or individual who promotes or advocates for respect of a human right, whether working locally or internationally, on a single subject or many, through any number of methods. Importantly, human rights defenders must always recognize the universality of human rights and employ nonviolence in their advocacy.25 In considering whether or not a person is a human rights defender, one must look at the activity undertaken by the person. Other considerations, such as whether or not the person is being paid for his or her work or belongs to a civil society organization, are not determinative.26 The Special Representative to the UN Secretary-General on the situation of human rights defenders has highlighted the pivotal role of human rights defenders in strengthening the preservation of democracy and its components.27 The Special Representative underscored that the presence of human rights defenders and the extent to which they are able to conduct their activities freely indicate the level of democratization of a State. Their work is also a motor for its further development.28 Despite the fact that they play a pivotal role in society, human rights defenders face challenges in some countries. While their experiences vary widely across countries and regions, in many areas, their rights to freedom of association have been suppressed by overt and covert government actions. The UN Special Rapporteur on the situation of human rights defenders has noted that many governments use limitations on the formation and registration of associations, as well as criminal sanctions for unregistered activities, to hinder human rights activities.29 Groups of human rights defenders in certain countries have also been denied the ability to solicit, receive or utilize funds.30 Human rights defenders around the world have also often been harassed by executive and judicial agents or censored through the use of slander laws or other regulations banning “extremism”.31 Moreover, some government entities have monitored and supervised the activities of some human rights defenders.32 23 Article 8(2) of the UN Declaration on Human Rights Defenders. 24 Article 9(3) of the UN Declaration on Human Rights Defenders. 25 Office of the High Commissioner for Human Rights, Fact Sheet No. 29: Human Rights Defenders, Geneva, 2004, pp. 2-5, 9-10. http://www.ohchr.org/Documents/Publications/FactSheet29en.pdf (Accessed August 2014). 26 Ibid. at pp. 6-8. 27 Report of the Special Representative of the Secretary-General on the situation of human rights defenders, UN Doc. E/CN.4/2003/104 (2003), para. 47. 28 Ibid. at para. 48. 29 Report of the Special Rapporteur on the situation of human rights defenders, UN Doc. A/64/226 (2009), paras. 50-56. 30 Report of the Special Rapporteur on the situation of human rights defenders, UN Doc. A/64/226 (2009), para. 55. 31 Ibid. at para. 56. 32 Ibid. at paras. 55, 93.