The following is based on a communication written by the UN Special Rapporteur on Human Rights Defenders and other UN experts to the Government of the Philippines on 9 February 2026. The communication remained confidential for 60 days before being made public, giving the Government time to reply. The Government acknowledged receipt of the communication on 17 February 2026. If more replies are received, they will be posted on the UN Special Procedures communications database.
At the time of publication, M. Tabada remains free on bail, with his next hearing scheduled for 17 July 2026.
This is a shorter version of the original communication.
BACKGROUND
Topic: the criminal prosecution on charges of ‘terrorist financing’ against Mr. Carmilo Tabada.
Mr. Carmilo “Eloy” Tabada is a human rights defender who previously served as the Bohol local centre coordinator of the non-governmental organisation Central Visayas Farmers Development Centre Inc (FARDEC). Founded in 1989, the organisation assists farmers in asserting their land rights and developing sustainable food production techniques in three provinces in the Central Visayas region in the Philippines. Mr. Tabada played an integral role in organizing farmers in Trinidad in Bohol province and in the development of the Trinidad-Talibon Integrated Farmers Association (TTIFA). In 2018 Mr. Tabada was an elected barangay councillor of Poblacion, in Trinidad and in 2023 he won re-election.
We previously raised concerns about the targeting of journalists, human rights defenders and activists in the Philippines in several communications to the Government. In particular, we wish to refer to communication AL PHL 5/2024, which requested details on any investigation carried out into the circumstances of the abduction in 2020 and subsequent death in 2021 of a colleague of Mr. Tabada. While we thank the government for its response to this communication, dated 11 April 2025, we regret that it neglected to comment on the case and provide the information requested, and we remain concerned.
ALLEGATIONS
In 2006, FARDEC began a sustainable agriculture progamme for local farmers in Bohol and in the following years the organisation contributed to the development of a potable water system, the establishment of a Department of Education-recognised primary school, as well as the setting up of a health centre and construction of a chapel. In 2009, FARDEC established a rice milling andmarketing facility, built on land that was awarded to TTIFA under the Comprehensive Agrarian Reform Programme of the government.
In 2015, FARDEC’s various projects began to come under greater military scrutiny and a campaign of intimidation and harassment of farmers associated with FARDEC started to occur in Bohol province. A military presence was established within the vicinity of a TTIFA community, and a raid was carried out on a warehouse storing rice at their facility, during which sacks of rice were punctured. Electricity to the warehouse and a nearby rice mill was cut. The mill was only able to resume its operations in 2016. During this time Mr. Tabada was working as Local Centre Coordinator for FARDEC, in which capacity he bought unhusked rice from farmers on behalf of the organisation.
From 2017 onwards, Mr. Tabada began to be subjected to routine surveillance and intimidation. He received several requests to meet with military officials, and on complying, he was placed under pressure to resign from FARDEC. In a congressional hearing on 5 November 2019, FARDEC was one of 18 organisations red-tagged by the Armed Forces of the Philippines (AFP) and the Department of National Defense (DND) and accused of being fronts for communist terrorist groups.
In March 2021, a group of unidentified men on motorcycles staged a demonstration outside of Mr. Tabada’s home in Trinidad, Bohol, accusing him of being a communist sympathiser and of storing weapons in his house. On 25 June 2021, officials from the Criminal Investigation and Detection Group (CIDG), the Philippine National Police and the AFP arrested Mr. Tabada at his home. Weapons were allegedly planted in his house during the arrest. Mr. Tabada was charged with illegal possession of firearms and explosives and was detained at Trinidad Police Station for three months before being transferred to Talibon police station until December 2022. In June 2023, the case against Mr. Tabada was dismissed by Regional Trial Court Branch 101 in Talibon, Bohol.
On 24 December 2024, charges of ‘terrorist financing’ under the Republic Act (RA) 10168 (Terrorism Financing Prevention and Suppression Act of 2012) were filed against Mr. Tabada. In February 2025, the witness in the prosecution’s case contacted Mr. Tabada and told him that he wanted to retract his statement. On 6 March 2025, the witness, accompanied by his lawyer and Mr. Tabada, appeared before the Provincial Legal Counsel at the Tagbilaran Capitol to swear-in his affidavit of retraction. Consequently, the Regional Trial Court granted a motion filed by Mr. Tabada’s attorney to hold in abeyance the arrest warrant for Mr. Tabada and ordered a reinvestigation of his case.
On 4 April 2025, the Prosecutor proceeded to indict Mr. Tabada and argued that bail should not be granted. A judge set bail at 150,000 pesos and on 19 May 2025, Mr. Tabada voluntarily presented himself to Regional Trial Court 101 in Talibon for his bail to be processed. He posted bail on 20 May 2025. In late July 2025, the case against Mr. Tabada was dismissed by a local court in Bohol for lack of jurisdiction.
Following this, the case was refiled by CIDG at the Regional Trial Court Branch 74 in Cebu City, a court designated to hear cases involving terrorist financing charges. A warrant for Mr. Tabada’s arrest was reportedly issued on 19 December 2025 and the following day he was arrested by personnel from the CIDG – Bohol and detained at Trinidad Municipal Jail in Bohol. He was released on bail on 23 December 2025 after posting the 200,000 pesos bail. His hearing has been set for 30 July 2026 at Regional Trial Court Branch 74 in Cebu City.
CONCERNS
In the communication, we express our deep concern about the continued criminalisation of Mr. Carmilo Tabada and especially his most recent criminal prosecution on charges of “financing terrorism”, in a context marked by several prior incidents of threats, harassment, red-tagging against him, including by State authorities, and his previous arbitrary arrest on charges which did not stand up in court but which resulted in his detention for over a year. We are worried that these actions may be taking place in direct connection with Mr. Tabada’s legitimate and important work as a human rights defender and the exercise of his rights to freedom of expression and freedom of association.
In previous communications, Special Rapporteurs already expressed serious concerns about the alleged misuse of the criminal charge of “financing terrorism” against human rights defenders, with notable due process concerns (PHL 7/2025; PHL 3/2024).
In her June 2025 report to the Human Rights Council on her visit to the Philippines (A/HRC/59/50/Add.3), the Special Rapporteur on freedom of opinion and expression, stated that the practice of red-tagging continued to be used especially against “those who are critical of government policies, advocate for human rights accountability and social justice or hold politically progressive views” and that it represents a “serious threat to civil society”.
In her most recent thematic report, the Special Rapporteur on freedom of peaceful assembly and of association also explicitly recognized red-tagging as a harmful practice contributing to the stigmatization of human rights defenders in the Philippines, which poses a serious and persistent threat to civil society in the country (see A/79/263, paras. 31-38, also referring to A/HRC/44/22, paras. 49 and 51).
We recall the recent ruling of the Supreme Court of the Philippines on 8 May 2025, which declared red-tagging, vilification, labelling, and guilt by association as a threat to people’s life, liberty, and security. Any criminalisation of human rights defenders due to unfounded accusations or labelling as communists or terrorists, is therefore inconsistent with this decision.
We refer the Government of the Philippines to concerns previously raised in several communications regarding the pattern of allegations of human rights violations and judicial harassment in the counter-terrorism context, including in PHL 5/2025, PHL 3/2024, PHL 4/2023, PHL 2/2023, PHL 1/2023, PHL 1/2022, PHL 6/2021, PHL 3/2021, PHL 1/2021. Furthermore, concerns were raised in PHL 4/2020 in regards to the Philippines’ overbroad and vague definition of terrorism and the designation of individuals and civil society and humanitarian organizations as “terrorists” pursuant to the Anti-Terrorism Act. We are alarmed that counter-terrorism measures appear to continue to be used to unduly restrict the legitimate activities of human rights defenders such as Mr. Tabada. We underscore, once again, the complementary and mutually reinforcing relationship between compliance with human rights treaties and standards and effective counter-terrorism measures, and remind the Government of its obligation to ensure full compliance of its counter-terrorism laws, policies, and measures with international law, including international human rights law, international humanitarian law, and international refugee law.
