Imbong vs. Ochoa, Jr.

Digest
April 8, 2014
G.R. Nos. 204819, 204934, 204957, 204988, 205003, 205043, 205138, 205478, 205491, 205720,
206355, 207111, 207172 & 207563
JAMES M. IMBONG, ET AL., Petitioners, v. HON. PAQUITO N. OCHOA, JR., ET AL.,
Respondents.
MENDOZA, J.:
FACTS:
The petitioners are one in praying that the entire RH Law be declared unconstitutional. Petitioner
ALFI, in particular, argues that the government sponsored contraception program, the very
essence of the RH Law, violates the right to health of women and the sanctity of life, which the
State is mandated to protect and promote.
ISSUES: 1) Whether or not RH Law is a violation of the prohibition on Riders.
HELD:

POLITICAL LAW: one subject-one title

The petitioners also question 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.
To belittle the challenge, the 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 separate.
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.

It cannot be denied that the measure also seeks to provide pre-natal and post-natal care as well. A
large portion of the law, however, covers the dissemination of information and provisions on access
to medically-safe, non-abortificient, effective, legal, affordable, and quality reproductive health care
services, methods, devices, and supplies, which are all intended to prevent pregnancy.
The Court, thus, agrees with the petitioners' contention that the whole idea of contraception
pervades the entire RH Law. It is, in fact, the central idea of the RH Law. Indeed, remove the
provisions that refer to contraception or are related to it and the RH Law loses its very foundation.
As earlier explained, "the other positive provisions such as skilled birth attendance, maternal care
including pre-and post-natal services, prevention and management of reproductive tract infections
including HIV/AIDS are already provided for in the Magna Carta for Women."
Be that as it may, the RH Law does not violate the one subject/one bill rule.