Title
Spouses Imbong vs. Ochoa, Jr.
Case
G.R. No. 204819
Decision Date
Apr 8, 2014
The Supreme Court upheld the RH Law's constitutionality, balancing public health interests with religious freedom, while striking down provisions infringing on conscientious objection rights.

Case Summary (G.R. No. 204819)

Background and Context of the Case

The consolidated cases challenge the constitutionality of the Responsible Parenthood and Reproductive Health Act of 2012 (RH Law), a legislation aimed at providing access to reproductive health information, family planning services, and responsible parenthood measures—particularly to poor and marginalized sectors. The petitioners raised various constitutional grounds related to the right to life, health, religious freedom, family privacy, and procedural due process as embodied under the 1987 Philippine Constitution.

Procedural Issues: Justiciability and Power of Judicial Review

  • The Supreme Court emphasized its duty to adjudicate actual controversies involving legally demandable and enforceable rights but highlighted that the petitions presented a justiciable controversy because the law had been enacted, and its implementing rules and budget were already in effect.
  • The principle of separation of powers commands judicial restraint regarding policy wisdom but mandates judicial review when grave abuse of discretion or constitutional violations occur.
  • The Court upheld the power of judicial review over both facial and as-applied challenges, especially when fundamental rights such as right to life and religious liberty are at issue.
  • The Court relaxed strict locus standi rules given the transcendental importance of the rights involved and the nationwide impact of the RH Law.
  • The petitions were not dismissed as mere advisory opinions but accepted for full consideration.

Substantive Issues and Court’s Analysis

1. Right to Life and Definition of Conception

  • The Constitution protects the life of the mother and the unborn from conception, understood in its plain and ordinary meaning to be the moment of fertilization of the ovum.
  • The Court rejected the contention that life begins only at implantation, relying on the text, medical dictionaries, and records of the 1986 Constitutional Commission deliberations which clarified conception equates to fertilization.
  • Contraceptives that act after fertilization to prevent implantation or destroy the fertilized ovum are abortifacients and are constitutionally prohibited.
  • The RH Law consistently prohibits abortifacients, defining them broadly as any drug or device causing abortion, destruction of a fetus, or preventing implantation upon FDA determination.
  • The FDA has the delegated authority to determine whether a contraceptive is abortifacient, subject to the Court’s mandated due process safeguards including transparency, public hearings, and representation of the State’s and unborn’s interests.
  • The Court declared void provisions in the Implementing Rules and Regulations (IRR) that introduced the qualifier “primarily” to the definition of abortifacient and contraceptive, as such redefinition would permit abortifacients disguised as contraceptives.
  • The “safe, legal, non-abortifacient” requirement in the RH Law’s Section 9 must be strictly interpreted to exclude products with any abortifacient effect.

2. Right to Health

  • The State has a constitutional duty to promote and protect people’s right to health.
  • The RH Law’s provisions on contraceptive access and family planning aim to reduce maternal and infant mortality, unintended pregnancies, and associated health complications.
  • Concerns about contraceptives’ side effects were acknowledged; however, the law mandates information dissemination, physician prescription requirements, and FDA regulation to ensure safe usage.
  • The Court found the challenge to Section 9’s inclusion of hormonal contraceptives and intrauterine devices as premature pending FDA evaluation.

3. Freedom of Religion and Religious Accommodation

  • Freedom of religion entails not only freedom to believe but also freedom to act according to beliefs, subject to compelling state interest and the least restrictive means.
  • The RH Law respects religious convictions by allowing conscientious objection (CO) exemptions for health providers who object to contraceptives or reproductive health services on religious or ethical grounds.
  • However, the Court held unconstitutional provisions compelling CO health providers, including hospitals owned by religious groups, to immediately refer patients to other providers for non-emergency reproductive health services.
  • The duty to refer was seen as burdensome and contrary to the free exercise clause because it forces indirect participation in acts considered morally repugnant by CO providers.
  • The Court clarified that the exemption for public officers mandated to implement the law excludes CO rights only for those officials directly tasked with enforcement; however, the IRR’s provisions denying CO to certain public health professionals unlawfully restrict religious freedom and violate equal protection.
  • The Court upheld the constitutionality of family planning seminar requirements for marriage licensure and the provision of reproductive health education in schools, provided curricular content respects religious views and is developed in consultation with parent-teacher associations.

4. Family and Privacy Rights

  • The Court recognized the family as the foundational social institution and marriage as inviolable, deserving protection.
  • The RH Law’s provision allowing one spouse to decide on reproductive health procedures over the objection of the other (in cases of disagreement) was declared unconstitutional for violating the right of both spouses to mutually decide on family planning matters, consistent with constitutional protections.
  • The law’s dispensation from parental consent for minors who are parents or have had miscarriages was declared unconstitutional, infringing parental authority and the natural and primary right to rear children.
  • The Court limited exceptions for access to information and emergency medical interventions without parental consent.

5. Due Process and Equal Protection

  • Challenges of vagueness and overbreadth were largely rejected with the Court emphasizing proper statutory construction and the self-executing nature of constitutional provisions.
  • The classification of priorities for the poor and marginalized in accessing reproductive health services was upheld under the equal protection clause as a valid and reasonable legislative policy.
  • The Court upheld the government’s power to delegate authority to the FDA to evaluate, register, and regulate reproductive health drugs and devices.
  • The obligation to render pro bono reproductive health services as a prerequisite for PhilHealth accreditation was upheld, but CO providers are exempted from providing services conflicting with their religious beliefs.

Final Disposition

The Supreme Court partially granted the petitions. The RH Law was declared constitutional in general, but was declared unconstitutional and struck down in the following respects:

  1. Sections 7 and corresponding IRR provisions, to the extent they:

    • Require private health facilities, non-maternity specialty hospitals, and religious hospitals to refer patients (non-emergency cases) to other providers.
    • Allow minors who are parents or had miscarriage to access modern family planning methods without parental consent.

  2. Section 23(a)(1) and corresponding IRR provision (Section 5.24), insofar as they impose a duty to disseminate reprod

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