Imbong v. Ochoa (G.R. No.

 204819)
Facts:

The increase of the country’s population at an uncontrollable pace led to the executive and the
legislative’s decision that prior measures were still not adequate. Thus, 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.

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 Section
26(1), Article VI of the Constitution, prescribing the one subject-one title rule. According to them, being
one for reproductive health with responsible parenthood, the assailed legislation violates the constitutional
standards of due process by concealing its true intent – to act as a population control measure. On the
other hand, 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:

Whether or not RH Law violated the one subject-one title rule under the Constitution

Ruling: 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. 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.

Be that as it may, the RH Law does not violate the one subject/one bill rule.

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.”

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:

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.

The one subject/one title rule expresses the principle that the title of a law must not be “so
uncertain that the average person reading it would not be informed of the purpose of the enactment
or put on inquiry as to its contents, or which is misleading, either in referring to or indicating one
subject where another or different one is really embraced in the act, or in omitting any expression
or indication of the real subject or scope of the act.”

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.

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.