[ GR No.

204819, Apr 08, 2014 ]

Imbong vs Ochoa
Maribeth Brown-Oliver, JD1B
Parties

JAMES M. IMBONG, petitioner

vs
PAQUITO OCHOA, respondent
Gist
Court faces the iuris controversy as presented in
fourteen (14) petitions and two (2) petitions-
in-intervention in the enactment of R.A. No.
10354, otherwise known as the Responsible
Parenthood and Reproductive Health Act of 2012
(RH Law)
Facts
Facts
◈ Congress enacted R.A. No. 10354, otherwise known as the
Responsible Parenthood and Reproductive Health Act of 2012 (RH
Law), to provide Filipinos, especially the poor and the
marginalized, access and information to the full range of modern
family planning methods, and to ensure that its objective to provide
for the peoples’ right to reproductive health be achieved. Stated
differently, the RH Law is an enhancement measure to fortify and
make effective the current laws on contraception, women’s health
and population control.
Facts
◈ Shortly after, challengers from various sectors of society moved to
assail the constitutionality of RH Law. Meanwhile, the RH-IRR for
the enforcement of the assailed legislation took effect. The Court
then issued a Status Quo Ante Order enjoining the effects and
implementation of the assailed legislation.
◈ Petitioners question, among others, the constitutionality of the RH
Law, claiming that it violates the following:
⬩ right to life of the unborn.
⬩ right to health and the right to protection against hazardous
products.
⬩ the right to religious freedom.
Facts

◈ Respondents insist that the RH Law is not a birth or

population control measure, and that the concepts of
“responsible parenthood” and “reproductive health”
are both interrelated as they are inseparable.
ISSUE
Issue

Whether or not RH Law violated the one

subject-one title rule under the Constitution
HELD
Held
◈ NO
◈ Despite efforts to push the RH Law as a reproductive
health law, the Court sees it as principally a
population control measure. The corpus of the RH
Law is geared towards the reduction of the country’s
population. While it claims to save lives and keep our
women and children healthy, it also promotes
pregnancy-preventing products.
 Held
◈ As stated earlier, the RH Law emphasizes the need to provide
Filipinos, especially the poor and the marginalized, with
access to information on the full range of modem family
planning products and methods. These family planning
methods, natural or modern, however, are clearly geared
towards the prevention of pregnancy. For said reason, the
manifest underlying objective of the RH Law is to reduce the
number of births in the country. The Court, thus, agrees with
the petitioners’ contention that the whole idea of contraception
pervades the entire RH Law.

◈
In Cawaling, Jr. v. COMELEC, it was written: It is well-settled that the
“one title-one subject” rule does not require the Congress to employ in
the title of the enactment language of such precision as to mirror, fully
index or catalogue all the contents and the minute details therein. The
rule is sufficiently complied with if the title is comprehensive enough as
to include the general object which the statute seeks to effect, and where,
as here, the persons interested are informed of the nature, scope and
consequences of the proposed law and its operation. Moreover, this
Court has invariably adopted a liberal rather than technical construction
of the rule “so as not to cripple or impede legislation.”
Held
In this case, a textual analysis of the various
provisions of the law shows that both
“reproductive health” and “responsible
parenthood” are interrelated and germane to the
overriding objective to control the population
growth. As expressed in the first paragraph of
Section 2 of the RH Law:
RH LAW
SEC. 2. Declaration of Policy. – The State recognizes and
guarantees the human rights of all persons including their right
to equality and nondiscrimination of these rights, the right to
sustainable human development, the right to health which
includes reproductive health, the right to education and
information, and the right to choose and make decisions for
themselves in accordance with their religious convictions, ethics,
cultural beliefs, and the demands of responsible parenthood.
Considering the close intimacy between
“reproductive health” and “responsible
parenthood” which bears to the attainment of the
goal of achieving “sustainable human
development” as stated under its terms, the Court
finds no reason to believe that Congress
intentionally sought to deceive the public as to the
contents of the assailed legislation.
Ruling
The Court declares R.A. No. 10354 as NOT
UNCONSTITUTIONAL except with respect to
certain provisions which are declared
UNCONSTITUTIONAL. The Status Quo Ante
Order issued by the Court is hereby LIFTED,
insofar as the provisions of R.A. No. 10354 which
have been herein declared as constitutional.