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.

HELD
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.