James M. Imbong, et. al. v. Hon. Paquito N. Ochoa, Jr., et. al.

G.R. No. 204819 | April 8, 2014
MENDOZA, J.

Due process: A statute or act suffers from the defect of vagueness when it lacks
comprehensible standards that men of common intelligence must necessarily guess its
meaning and differ as to its application.
Freedom of Religion: The Court will not rule on ecclesiastical matters. Conscientious
objectors are, as held by the Court, exempted as long as the Reproductive Health Bill goes
against their religious beliefs.

FACTS

This case involves consolidated petitions for certiorari and prohibition against the implementation
of the Reproductive Health Law.
• The Reproductive Health Law was passed.
• A TRO was issued against its implementation.
• The Court issued a Status Quo Ante order.
• Petitioners assail the constitutionality of the RH law for being vague as to ‘private healthcare
service institution,’ and that it fails to define ‘incorrect information.’
• Petitioners also assail that it violates equal protection because of its mandatory application to
only to ‘public schools,’ and that it discriminates against the poor by making them the primary
target of the government programs.

ISSUES AND HOLDING

1. Whether Section 23 (a)(I) is void for vagueness. No.

• A vague statute violates both procedural and substantive due process because it –
1. Fails to inform its subjects of the conduct to do or to refrain from; and
2. Gives the enforcing authority unbridled discretion in determining what or
whom are punishable under the statute.
• ‘Institution’ and ‘service provider’ are used synonymously in the law.
• As to the ‘private healthcare service provider,’ the Court agreed with the Office of the
Solicitor General (OSG) that its definition should be taken from the definition of
‘public healthcare service providers’ under section 4 of the law.
• Plain meaning rule used for ‘incorrect information.’
§ From its plain meaning, the word "incorrect" here denotes failing to agree
with a copy or model or with established rules; inaccurate, faulty; failing to
agree with the requirements of duty, morality or propriety; and failing to
coincide with the truth.
§ The word "knowingly" means with awareness or deliberateness that is
intentional.

2. Whether Section 14 violates the equal protection clause. No.

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• The requisites of a valid classification are:
1. It must rest on substantial distinctions;
§ Discrimination of the poor –
• Article XIII of the Constitution provides that health
development programs should prioritize the
underprivileged, the same goes with the reason that many of
the underprivileged go to public schools.
§ Private schools and public schools –
• It is important to recognize academic freedom of private
schools, especially with respect to religious instruction and
their sensitivity towards the teaching of reproductive health
education.
2. It is germane to the purpose of the law;
§ It is expressly mentioned in Section 2 (Declaration of Policies) that
one of the purposes of the law is for the reduction of poverty, with the
assistance of the National Household Targeting System for Poverty
Reduction (NHTS-PR).
3. It is not limited to existing conditions only; and
4. It must apply to all members of the same class.
§ It is not necessary that the classification be made with absolute
symmetry, in the sense that the members of the class should possess
the same characteristics in equal degree.

3. Whether the RH Law violates freedom of religion. Yes.

• The Court will not rule on ecclesiastical matters. Conscientious objectors are, as held
by the Court, exempted as long as the Reproductive Health Bill goes against their
religious beliefs. Hence, the following provisions are unconstitutional as they infringe
upon the freedom of religion of conscientious objectors.
§ Section 23(a)(1) which punishes any healthcare service provider who refuses
to disseminate information regarding programs and services on reproductive
health regardless of his or her religious beliefs.
§ Section 23(a)(3) which punishes healthcare service providers who fail or
refuse to refer a patient to another healthcare service provider within the same
facility regardless of his or her religious beliefs.
§ Section 23(b) which punishes any public officer who refuses to support
reproductive health programs regardless of his or her beliefs.
§ Section 17 regarding pro bono services insofar as they affect the
conscientious objector in securing PhilHealth accreditation.

Petition is PARTIALLY GRANTED. RA 10354 is NOT UNCONSTITUTIONAL.
Except with the following provisions declared UNCONSTITUTIONAL: Section 7 | Section
23(a)(1) | Section 23(a)(2)(i) | Section 23(a)(2)(ii) | Section 23(a)(3) | Section 23(b) | Section
17 | Section 3.01(a) | Section 3.01G

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