G.R. No. 204819: James M. Imbong v. Hon. Paquito N. Ochoa, Jr., et al.

Overview

• Date of Decision: April 8, 2014
• Court: Supreme Court of the Philippines, En Banc
• Justices: Mendoza (J, Decision), Sereno (CJ, Concurring and Dissenting), Del Castillo (J, Concurring and Dissenting), Reyes (J, Concurring and Dissenting), Perlas-Bernabe (J, Concurring and Dissenting), Carpio (J, Concurring), Leonardo-De Castro (J, Concurring), Abad (J, Concurring), Brion (J, Separate Concurring), Leonen (J, Dissenting)
• Petitioners: James M. Imbong and others
• Respondents: Hon. Paquito N. Ochoa, Jr. and others

Key Issues

1. Constitutionality of the RH Law (R.A. No. 10354)

   • Petitioners argued it violated constitutional rights, including the right to life, health, religious freedom, and equal protection.
   • Main concerns were about abortion, freedom of religious exercise, and parental authority.

2. Judicial Review and Procedural Issues

   • Actual case or controversy and ripeness for judicial review.
   • Legal standing (locus standi) of the petitioners.
   • Whether the case presented was a declaratory relief or an action suitable for judicial review.

3. Religious Freedom and Conscientious Objectors

   • Imposition of duties contrary to religious beliefs, such as referral for contraceptives.
   • Compelling state interest vs. individual rights.

4. Parental Rights and Family Privacy

   • Parental consent for minors in reproductive health procedures.
   • Consent of spouses for reproductive health procedures.

5. Principle of Non-Delegation and Due Process

   • Delegation to the FDA on determining non-abortifacient contraceptives.
   • "Void-for-vagueness" doctrine and clarity of law provisions.

Court's Decision

• Constitutional Outcome: The RH Law was largely upheld but several provisions were struck down as unconstitutional.
• Invalidated Provisions: (Section numbers reference R.A. No. 10354)
  • Section 7: Requirement for religious institutions to refer patients for reproductive services, and access for minors without parental consent.
  • Section 23(a)(1, 2, 3): Penalizing health workers for non-compliance; requirement to refer against religious beliefs not allowed.
  • Section 17: Mandatory pro bono service affecting conscientious objectors.
  • Implementing Rules and Regulations (IRR): Definitions altering legal scope beyond the statute.

Important Legal Principles

• Freedom of Religion: Strong emphasis on protecting religious beliefs from state interference. Conscientious objectors cannot be compelled to act against their beliefs.
• Parental Authority: Recognition of parental rights and the need for consent, highlighting the family as a fundamental social institution.
• Judicial Restraint and Legislative Intent: Court respects legislative intent but intervenes where constitutional rights are threatened.

Context and Implications

• The decision highlights the balance between state objectives in public health and individual constitutional rights.
• Emphasis on protecting individual rights without compromising state duties in public welfare.
• The ruling sets a precedent in interpreting laws affecting religious freedoms and personal rights in the context of national policy.