Digest Imbong Vs Ochoa

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 and due
process clause. 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 (WON) RA 10354/Reproductive Health (RH) Law is unconstitutional for
violating the due process clause.
Ruling: NO. The RH Law does not violate the due process clause of the Constitution as the
definitions of several terms as observed by the petitioners are not vague.
The definition of “private health care service provider” must be seen in relation to Section 4(n)
of the RH Law which defines a “public health service provider”. The “private health care
institution” cited under Section 7 should be seen as synonymous to “private health care service
provider.
The terms “service” and “methods” are also broad enough to include providing of information
and rendering of medical procedures. Thus, hospitals operated by religious groups are
exempted from rendering RH service and modern family planning methods (as provided for by
Section 7 of the RH Law) as well as from giving RH information and procedures.
The RH Law also defines “incorrect information”. Used together in relation to Section 23 (a)(1),
the terms “incorrect” and “knowingly” connote a sense of malice and ill motive to mislead or
misrepresent the public as to the nature and effect of programs and services on reproductive
health.
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.

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IMBONG V. OCHOA (G.R. NO.

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