Lawyerly

FACTS:

The framers of the common law highly valued freedom of religion, and the Court has maintained this principle to allow individuals to live by their religious beliefs, while respecting the rights of others. Despite the nation facing challenges such as poverty, hunger, illiteracy, and unemployment, the legislation aims to address societal woes. The issue of population growth control has been divisive, but the Responsible Parenthood and Reproductive Health Act of 2012 (RH Law) was enacted by Congress on December 21, 2012. Following its enactment, various sectors challenged its constitutionality by filing fourteen petitions and two petitions-in-intervention. These petitions were from groups and individuals, such as spouses Attys. James and Lovely Ann Imbong, Alliance for the Family Foundation Philippines, various citizens and taxpayers, and institutions like the Task Force for Family and Life Visayas, Serve Life Cagayan De Oro City, and Couples for Christ Foundation, among others. The petitions argued that the RH Law violated constitutional rights, primarily focusing on the right to life, right to health, and right to religious freedom, among other concerns. They contended that the Law would authorize hazardous contraceptives, violate religious freedoms by using public funds to purchase contraceptives, infringe on freedom of speech, equal protection, and parental rights, and was vague and ambiguous. On March 15, 2013, the RH Law’s Implementing Rules and Regulations took effect, but a Status Quo Ante Order was issued by the Court on March 19, 2013, suspending the law's implementation until further notice.

ISSUES:

PROCEDURAL Whether the Court may exercise its power of judicial review over the controversy.
1. Power of Judicial Review
2. Actual Case or Controversy
3. Facial Challenge
4. Locus Standi
5. Declaratory Relief
6. One Subject/One Title Rule
SUBSTANTIVE Whether the RH Law is unconstitutional:
1. Right to Life
2. Right to Health
3. Freedom of Religion and the Right to Free Speech
4. The Family
5. Freedom of Expression and Academic Freedom
6. Due Process
7. Equal Protection
8. Involuntary Servitude
9. Delegation of Authority to the FDA
10. Autonomy of Local Governments and the ARMM

RULING:

Procedural Issues

Power of Judicial Review: The Court affirmed its authority of judicial review, citing the principle of separation of powers and the explicit constitutional mandate to determine the constitutionality of acts by the Executive and Legislature. Acts within their competence and authority are to be respected unless there is grave abuse of discretion.
Actual Case or Controversy: The Court found that an actual case or controversy exists because the RH Law and its implementing rules have already taken effect, presenting a justiciable controversy.
Facial Challenge: The Court decided that the RH Law could be subjected to a facial challenge as it seriously alleges violations of human rights to life, speech, and religion.
Locus Standi: The Court applied a liberal approach to the standing of petitioners due to the transcendental importance of the issues, allowing them to challenge the RH Law.
Declaratory Relief: The Court recognized the petitions could be considered as petitions for prohibition under Rule 65, over which it has original jurisdiction.
One Subject/One Title Rule: The RH Law does not violate this rule as its title sufficiently covers the general object of the statute.

Substantive Issues

Right to Life: The Court ruled that the RH Law does not sanction abortion and mandates non-abortifacient contraceptives, thus not violating the right to life.
Right to Health: The Court found that adequate safeguards exist under the RH Law, and any attack on the RH Law on this ground is premature as the FDA has yet to determine the safety of contraceptives to be used under the law.
Freedom of Religion and the Right to Free Speech:

The duty to refer under Section 23(a)(3) was ruled as violative of religious freedom.
The Court struck down Section 7 and sections of the law regarding forced referrals and Section 23(a)(1) on providing information against religious beliefs.
Section 23(a)(2)(i) on spousal consent and Section 23(a)(2)(ii) on parental consent in non-elective surgical procedures were also struck down.

The Family: The Court ruled that provisions interfering with spousal consent and parental consent, as specified in the RH Law, were unconstitutional.
Freedom of Expression and Academic Freedom: Provisions regarding mandatory reproductive health education in Section 14 were not yet ripe for judicial determination and thus their constitutionality was not ruled upon.
Due Process: The Court did not find the RH Law violative of the due process clause as it provided sufficient definition and standards.
Equal Protection: The Court ruled that prioritizing the poor in accessing reproductive health services is not a violation of the equal protection clause, and exclusion of private educational institutions from mandatory reproductive health education was justified.
Involuntary Servitude: Compelling healthcare service providers to render pro bono reproductive health services, with respect to PhilHealth accreditation, was ruled not to amount to involuntary servitude. However, conscientious objectors must be exempt from this provision.
Delegation of Authority to the FDA: The delegation to the FDA to determine what contraceptives and reproductive health services are included in the EDL was found valid.
Autonomy of Local Governments and the ARMM: The provisions do not violate local autonomy or the autonomy of the ARMM as the national government retains authority over nationally funded programs and services, including those outlined in the RH Law.

PRINCIPLES: