Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Killings and repression of defenders · Philippines · 2023–2025

Philippines activists Castro and Tamano disappearance

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured. Disputed
What the record lacks: 1 none on record · 2 insufficient · 1 not measured · 2 disputed · 2 unclear See the gaps
Accounts of the harm differ
Did Manila Bay reclamation harm the bay's fishers?
  • Communities and civil society A fishers' organisation: Dredging in Cavite continued after the suspension of Manila Bay reclamation; the organisation said small fishers' income fell by 80–90%. Philippine Daily Inquirer
  • Government and regulators Environment department: Suspended all Manila Bay reclamation projects in August 2023 (22 projects), with 2 allowed to resume in November. ABS-CBN News (citing PNA)

Two activists who opposed land reclamation in Manila Bay were abducted in Bataan in September 2023. The Supreme Court granted them protection writs and found elements of enforced disappearance.

Elements of enforced disappearanceSupreme Court finding
Writs of amparo and habeas data granted; ruling dated 24 October 2023, released 15 February 2024.

Status As of April 2026: the Supreme Court protection order was reported upheld in December 2025; the sources reviewed show no criminal ruling.

What?
Two anti-reclamation advocates were abducted; the Supreme Court found elements of enforced disappearance. Supreme Court of the Philippines (via Lawphil)
Where?
Orion, Bataan, and Manila Bay, Philippines; ruling by the Supreme Court in Manila. Supreme Court of the Philippines (via Lawphil)
When?
Abduction on 2 September 2023; decision dated 24 October 2023, released 15 February 2024. Supreme Court of the Philippines (via Lawphil)
Who?
Gained
  • Boskalis — Dredging work covered by €1.5bn of Atradius DSB insurance for San Miguel's airport reclamation. Both ENDS
Lost
Harmed
  • Small-scale fishers (as stated by a fishers' organisation) — Reported income falls of 80–90%; not independently verified. Philippine Daily Inquirer
Why?
The two opposed land reclamation in Manila Bay. A UN Special Rapporteur said in 2023 that the anti-communist task force NTF-ELCAC "is using its powers to protect key economic interests in the country" (report A/HRC/56/46/Add.2).
How?
The army presented the two as surrenderers; they said they had been abducted. The Court granted amparo and habeas data writs. Supreme Court of the Philippines (via Lawphil)
6 of 6 questions answered from the record

What happened

The record, in order.

Jonila Castro and Jhed Tamano, members of AKAP KA Manila Bay, were anti-reclamation advocates in Manila Bay. They were abducted on 2 September 2023 in Orion, Bataan.

The army presented the two as surrenderers. At that event they said they had been abducted.

The Supreme Court granted writs of amparo and habeas data and a protection order, and found elements of enforced disappearance. The decision is dated 24 October 2023 and was released on 15 February 2024. A December 2025 report said the Supreme Court had upheld the protection order.

In May 2022 the Dutch export credit agency Atradius DSB had given the dredging company Boskalis €1.5bn of insurance cover for San Miguel's airport reclamation in Manila Bay, according to a Both ENDS press release.

In August 2023 the environment department suspended all Manila Bay reclamation projects: 22 were suspended and 2 were later allowed to resume in November.

  1. 2022May: Atradius DSB gives Boskalis €1.5bn of insurance cover for San Miguel's airport reclamation
  2. 202310 August: all Manila Bay reclamation projects reported suspended; 2 September: Castro and Tamano abducted in Orion, Bataan; 24 October: Supreme Court decision granting amparo and habeas data writs; 2 projects allowed to resume in November
  3. 202415 February: Supreme Court decision released; Court of Appeals reported to have denied the writs in August
  4. 2025December: Supreme Court reported to have upheld the protection order

What was said

Claims, in the words of those who made them.

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

How did the two activists come to be in army custody?
Government and regulators
The army

Presented the two as surrenderers.

Communities and civil society
Castro and Tamano

At the army event they said they had been abducted.

Courts
Supreme Court of the Philippines

Granted writs of amparo and habeas data and a protection order, finding elements of enforced disappearance.

Supreme Court of the Philippines (via Lawphil)
Did Manila Bay reclamation harm the bay's fishers?
Communities and civil society
A fishers' organisation

Dredging in Cavite continued after the suspension of Manila Bay reclamation; the organisation said small fishers' income fell by 80–90%.

Philippine Daily Inquirer
Government and regulators
Environment department

Suspended all Manila Bay reclamation projects in August 2023 (22 projects), with 2 allowed to resume in November.

ABS-CBN News (citing PNA)

How it looked

What was shown, beside what was recorded.

Shown

  • The two activists were presented as surrenderers at an army event.
    The army

Recorded

  • The Supreme Court granted writs of amparo and habeas data plus a protection order and found elements of enforced disappearance.
  • The protection order was reported upheld in December 2025.
  • Atradius DSB gave Boskalis €1.5bn of insurance cover in May 2022 for San Miguel's airport reclamation.

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: EUR · Window: . All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • Supreme Court of the Philippines (24 October 2023 (released 15 February 2024)): Granted writs of amparo and habeas data and a protection order; found elements of enforced disappearance. · Supreme Court of the Philippines (via Lawphil)

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2023-10-24 (released 2024-02-15)Claimant won
    Petition for writs of amparo and habeas data (G.R. No. 269249)
    Supreme Court of the Philippines · Civil · Jonila Castro and Jhed Tamano → Not stated in the sources reviewed

    The Court granted writs of amparo and habeas data and a protection order and found elements of enforced disappearance. A December 2025 report said it upheld the protection order. Supreme Court of the Philippines (via Lawphil)

Insurers

  1. 2022No policy found€1.5bn Insurance cover
    Atradius DSB (Dutch export credit agency) → Boskalis

    Atradius DSB gave Boskalis €1.5bn of insurance cover in May 2022 for San Miguel's airport reclamation, according to a Both ENDS press release. No claim is recorded. Both ENDS

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Reclamation projects suspended
22
Environment department, August 2023; 2 allowed to resume in November
Small-fisher income
Down 80–90%
Claim by a fishers' organisation, as reported by the Inquirer; not independently verified
Independent ecological evaluation
Not on record
The sources reviewed do not include one

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.
  • Disputed Did Manila Bay reclamation harm the bay's fishers?

Insurers

  • Unclear Atradius DSB (Dutch export credit agency): no decision on record.

Figures

  • Insufficient Small fisher income drop pct: Claim by a fishers' organisation reported by the Inquirer.

Accounts

  • Disputed How did the two activists come to be in army custody?

Record

  • Unclear The Court of Appeals denied the writs in August 2024; how this relates to the Supreme Court grant is unclear in the sources reviewed.
  • None on record The sources reviewed give two framings of the Supreme Court decision date: a decision dated 24 October 2023 and an announcement in February 2024.
  • Insufficient Reported but not independently verified: the exact wording of the activists' statement at the army event that they had been abducted.

Did the harm stop?

Reclamation projects were suspended in August 2023, before the abduction on 2 September 2023. Two were allowed to resume in November 2023.

Who paid?

The two activists, who were abducted. The record also states that small-scale fishers' groups reported income losses from Manila Bay reclamation.

Sources

Voices on record: — Company or project✓ Government and regulators✓ Courts✓ Press and investigations✓ Communities and civil society— Researchers

Government and regulators

Courts

  1. Supreme Court decision, G.R. No. 269249 (24 October 2023)
    Supreme Court of the Philippines (via Lawphil) · 2023-10-24

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.