IMBONG VS OCHOA

G.R. No. 204819 April 8, 2014

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.