RH Law Comment Lagman

Republic of the Philippines ..
SUPREME COURT " ' '. ro I, \

... 1 ' .. \t;
Manila
EN BANC
JAMES M. IMBONG and LOVELY-
ANN C. IMBONG, et al.,
Petitioners
-versus-
HON. PACQUITO N. OCHOA, JR., et al.,
Respondents
x--------------------------------------x
AlliANCE FOR THE FAMILY FOUNDATION
PHILIPPINES, INC. (ALFI), et al-,
Petitioners
-versus-
HON. PACQUITO N. OCHOA, Executive
Secretary, et al.,
Respondents
x--------------------------------------x
SJS PRESIDENT SAMSON S. AlCANTARA,
Petitioner-in-Intervention
-versus-
l-ION. PACQUITO N. OCHOA, JR., et al.,
Respondents
x--------------------------------------x
TASK FORCE FOR FAMILY AND LIFE
VISAYAS, INC. and VALERIANO S. AVILA,
Petitioners
;_ i I o' V
G.R. No. 204819
G. R. No. 204934
G.R. No. 204934
-versus-
I " ~ O N . PACQUITO N. OCHOA, JR., et al./
Re:,-pondents
x--------------------------------------x
SERVE liFE CAGAYAN DE ORO CITY, INC.,
et al./
Petitioners
-versus-
OFFICE OF THE PRESIDENT, SENATE OF
THE PHILIPPINES, HOUSE OF
REPRESENTATIVES, et al./
Respondents
x--------------------------------------x
EXPEOITO A. BUGARIN,
Petitioner
-versus-
OFFICES OF THE HON. PRESIDENT OF
THE REPUBLIC OF THE PHILIPPINES,
riON. SENATE PRESIDENT, HON. SPEAKER
OF THE HOUSE OF REPRESENTATIVES
AND HON. SOLICITOR GENERAL;
Respondents
x--------------------------------------x
EDUARDO B. OlAGUER and the CATHOLIC
XYBR APOSTOLATE OF THE PHiliPPINES,
Petitioners
-versus-
DOH SECRETARY ENRIQUE T. ONA,
Respondent
x--------------------------------------x
G.R. No. 204951
G.R. No. 204988
G. R. No. 205003
G.R.No.205043
)
REYNALDO I. ECHAVEZ, MD., et al.,
Petitioners
-versus-
HON. PACQUITO N. OCHOA, JR.
1
et al.
Respondents
x--------------------------------------x
Spouses FRANCISCO S, TATAD and MA.
FENY C. TATAD, et al.,
Petitioners
-versus-
OFFICE Of THE PRESIDENT OF THE
REPUBLIC OF THE PHILIPPINES,
Respondent
x--------------------------------------x
G.R. No. 205478
G.R. No. 205491
MOTION FOR lEAVE TO APPEAR AS
RESPONDENT-IN-INTERVENTION WITH ATTACHED
"COMMENT-IN-INTERVENTION'' AND
APPEARANCE AS COUNSEL FOR RESPONDENT HOUSE OF
REPRESENTATIVES (G.R. No. 204988 AND G.R. No. 205003) IN
COLLABORATION WITH THE SOLICITOR GENERAL
rv10VANT Rep. Edcel C. Lagman respectfully manrfests that:
1. He is the acknowledged principal author and main sponsor in the House of
Representatives of House Bill No. 4244, entitled "An Act Providing for a Comprehensive
Policy on Responsible Parenthood, Reproductive Health, and Population and
Development and For Other Purposes", which has been enacted as Republic Act No.
10354 or the "Responsible Parenthood and Reproductive Health Act of 2012",
hereinafter referred to as the Reproductive Health Law.
2. Herein Movant was also the principal author and sponsor of the precursor bills
-- House Bill No. 3773, entitled "Responsible Parenthood and Population r"lanagement
Act of 2005" during the 13th Congress; and House Bill No. 5043, entitled "Reproductive
Health, Responsible Parenthood and Population Development Act of 2008" during the
3. Even when he vvas not a Member of the 11th and 12th Congresses due to the
expiration of his third consecutive term after the lOth Congress
1
he was active in
advocating for the passage of the earlier bills - House Bill No. 8110, entitled "The
Integrated Population and Development Act of 1999" in the 11th Congress, and House
Bill No. 4110, entitled "An Act Establishing a Reproductive Health Care Act,
Strengthening Its Implementing Structures, Appropriating Funds Therefor and For Other
Purposes" in the 12tt
1
Congress.
4. During the 13-year saga for the enactment of the Reproductive Health Law,
the herein fvlovant and the other reproductive health advocates have thoroughly studied
the constitutionality of the Reproductive Health Bill and they are of the firm position that
the Reproductive Health Law is free from any and all constitutional infirmities, and that
it is absolutely and indubitably constitutional because:
a) It does not vitiate the right to life;
b) Contraceptives are not abortifacients;
c) It does not infringe on the right to health but rather protects and
promotes maternal and infant health;
d) It does not violate freedorn of religion but fully respects religious
conviction and freedom of informed choice; and
4
e) It does not supplant the right of parents in developing the moral character
of the youth but supports such parental right by providing for age and
development-appropriate reproductive health education for adolescents.
5. As a ~ ~ e m b e r of the 15th Congress, and more particularly as the principal
author and main sponsor of the Reproductive Health Law, he has the legal standing and
abiding interest to defend its constitutionality and align himself as intervenor with the
public respondents in accordance with Rule 19 of the Rules of Civil Procedure.
6. The projected intervention will not unduly delay or prejudice the adjudication
of the rights of the original parties, and the herein movant's rights as intervenor cannot
be fully protected in a separate proceeding.
7. The Honorable Supreme Court in Province of North Cotabato vs. the
Government of the Republic of the Philippines Peace Panel of Ancestral
Don1ain (GRP), [G.R. 183591, October 14, 2008] ruled that a "Member of the House
of Representatives has a standing to maintain inviolate the prerogatives, powers and
privileges vested by the Constitution in his office."
8. In Senate of the Philippines vs. Ermita (486 SCRA 1), the Honorable
Supreme Court reiterated that "indeed, legislators have standing to maintain inviolate
the prerogatives, powers and privileges vested by the Constitution in their office and are
allowed to sue to question the validity of any official action which they claim infringes
their prerogatives as legislators".
9. If legislators or Members of the Congress can sue as petitioners to challenge
the constitutionality of certain statues or executive orders, then by parity of reasoning a
iVJember of Congress has the legal personality to defend the constitutionality of a
statute, like in the case at bar, which is the deliberate and earnest product of his office's
prerogatives, powers and privileges.
10. It is relevant to stress that the Honorable Supreme Court has adopted the
rule that even where the petitioners have failed to show direct injury, they have been
allowed to sue under the principle of "transcendental importance." In David vs.
Macapagai-Arroyo ( 489 SCRA 160), it was ruled that:
"However, being a mere procedural technicality, the requirement
of locus standi may be waived by the Court in the exercise of its
discretion. This was done in the 1949 Emergency Power Cases,
Araneta v. Dinglasan, where the 'transcendental importance' of
the cases prompted the Court to act liberally. Such liberality was
neither a rarity nor accidental. In Aquino v. C o m e l e c ~ this Court
resolved to pass upon the issues raised due to the 'far-fetching
implications' of the petition notwithstanding its categorical
statement that petitioner therein had no personality to file the suit.
Indeed, there is a chain .of cases where this liberal policy has been
observed, allowing ordinary citizens, members of Congress, and civic
organizations to prosecute actions involving the constitutionality or
validity of laws, regulations and rulings."
11. In the landmark Emergency Powers Cases, the Honorable Supreme Court
ruled that "the transcendental importance to the public of these cases demands that
they be settled promptly and definitely, brushing aside, if we must, technicalities of
procedure.'/ (Kilosbayan vs. Guingona, 232 SCRA 110).
c:.
12. In the same measure, the transcendental importance of resolving the
constitutionality of the Reproductive Health Law justifies the intervention of the herein
t1ovant in sustaining the constitutionality of the challenged Act.
13. Moreover, as a family man, herein fVjovant has a legal interest to protect in
defending the validity of the Reproductive Health Law because he has children and
grandchildren who will benefit from the progressive and enlightened provisions of the
law.
14. It also needs emphasis that in G. R. No. 204988, entitled "Serve Life
c:agayan de Oro City Inc., et a/. vs. Office of the President, Senate of the
Philippines, House of Representatives, et and G. R. No. 205003, entitled
"Expedito A. Bugarin, Jr. vs. Office of the Hon. President of the Republic of
the Philippines, Hon. Senate President, Hon. Speaker of the House of
Representatives and Hon. Solicitor the House of Representatives was
named one of the respondents.
15. Honorable Feliciano Belmonte, Jr., Speaker of the House of Representatives,
has authorized the herein Movant to appear before the Honorable Supreme Court in
collaboration with the Solicitor General on behalf of the House of Representatives in the
aforementioned cases, with the prior conformity of Solicitor General Francis H.
Jardeleza.
16. Attached as Annex "1" is the adverted authorization contained in a letter
dated 16 April 2013 from Speaker Feliciano Belmonte, Jr.
7
17. Attached as Annex "2" is the herein Movant's "Comment-in-Intervention"
traversing the petitioners' purported arguments questioning the constitutionality of the
Reproductive Health Law in the above-captioned petitions.
PRAYER
ACCORDINGLY, herein Movant respectfully prays that the Honorable Supreme
Court:
1. Grants him leave to appear as party Respondent-in-Intervention;
2. Allows him to appear as counsel for the respondent House of Representatives
in collaboration with the Solicitor General;
3. Admits the attached Comment-in-Intervention; and
4. Considers the Comment-in-Intervention as part of the Comment of the
respondent House of Representatives.
Quezon City, for Manila
19 April 2013
--------------,

EDcEL
Member, House of Representatives
Roll of Attorneys No. 21381
PTR No. 8189823; 04-16-2013 (Quezon City)
IBP No. 923026 (CALMANA)
fvJobile No. 0916-6406737
Honorable Clerk of Court
The Supreme Court
En Bane
GREETINGS:
NOTICE
Please submit the foregoing "Motion for Leave to Appear as Respondent-in-
Intervention and File Comment-in-lntervention/1 for the consideration of the Honorable
Supreme Court immediately upon receipt thereof.
EXPLANATION
This "Motion for Leave to Appear as Respondent-in-Intervention and File
Comment-in-Intervention /I is filed personally with the Honorable Court and copies
thereof served on the parties, through counsel, by registered mail due to personnel
constraints.
Copy furnished:
IMBONG & CASTRO LAW OFFICES
Counsel for the Petitioners in
GR No. 204819
Unit 403 Senor Ivan de Palacio Building
J 39 Malakas St., Diliman, Quezon City
MCS Noche law Office
GR No. 204934
91 Melchor St., Loyola Heights, 1108
Quezon City
~ ~ '
EDCEl C. LAGMAN
Quezon City Hall Post Office
Registry Receipt No. __ _
_ April 2013
ATTY. SAMSON S. ALCANTARA
Petitioner-in-Intervention in
GR No. 204934
Suite 1402
1
14th Floor, Manila Astral
Tower, Taft Avenue cor. Padre Faura St.
Ermita, fVlanila
fv1.B. P..i!AfiiNAY & ASSOCIATES
GR No. 204957
Diamond St. cor. Jade St. Francisca
Village 6th Street, Happy Valley, Cebu City
GAMBE & YAP LAW OFFICES
GR iVo. 204988
Mandumol Upper Makasandig,
Cagayan de Oro City
ATTY. EXPEDITO A. BUGARIN, JR.
Petitioner in GR No. 205003
No. 19 Country Club Village
Banilad, Cebu City
ATTY. NELSON A. CLEMENTE
GR No. 205043
Penthouse, Aurora Milestone Tovver
1045 Aurora Boulevard, Quezon City
CAllEJA LAW OFFICE
GR No. 205478
lJnit 1903-A West Tower
PSE Centre Exchange Road, Ortigas Center
Pasig City
ATTY. ALAN F. PAGUIA
GR No. 205491
Corporate 101 Building (Unit 412)
101 Mother Ignacia St., Barangay
South Triangle, Quezon City
THE SOLICITOR GENERAL
Counsel for the Respondents
134 Amorsolo St., Legaspi Village
1229 Makati City
_ April 2013
Registry Receipt No. __
__ April 2013
_ April 2013
_ April 2013
_ April 2013
_ April 2013
_ April 2013
__ April 2013
1n
REPUBLIC OF THE PHILIPPINES
QUEZON CITY Sc.
AFFIDAVIT OF SERVICE
I, SEAN DABU, as messenger of Lagman Lagman and Mones Law Firm, with postal
address at 2/F Tempus Place II Condominium, Makatarungan and Matalino Streets, Diliman,
Quezon City, after being duly sworn to in accordance with law, hereby depose and say:
Tl1at on 23 April 2013, I served a copy of the following pleading/paper:
Nature of Pleading/Paper
MOTION FOR LEAVE TO APPEAR AS RESPONDENT-IN-INTERVENTION WITH
ATTACHED "COMMENT-IN-INTERVENTION" AND APPEARANCE AS COUNSEL
FOR RESPONDENT HOUSE OF REPRESENTATIVES (G.R. No. 204988 AND G.R.
No. 205003) IN COLLABORATION WITH THE SOLICITOR GENERAL
In SC- G.R. No. 204819, "JAMES M. IMBONG and LOVELY-ANN C. IMBONG, et al., VS.
HON. PACQUITO N. OCHOA, JR., et al., G.R. No. 204934, ALLIANCE FOR THE FAMILY
FOUNDATION PHILIPPINES, INC. (ALFI), et al. VS. HON. PACQUITO N. OCHOA, Executive
Secretary, et al., G.R. No. 204934, SJS PRESIDENT SAMSON S. ALCANTARA VS HON.
PACQUITO N. OCHOA, JR., et al., G.R. No. 204957, TASK FORCE FOR FAMILY AND LIFE
VISAYAS, INC. and VALERIANO S. AVILA VS. HON. PACQUITO N. OCHOA, JR., et al..
G.R. No. 204988, SERVE LIFE CAGAYAN DE ORO CITY, INC., et al. VS. OFFICE OF THE
PRESIDENT, SENATE OF THE PHILIPPINES, HOUSE OF REPRESENTATIVES, et al., G.R.
No. 205003, EXPEDITO A. BUGARIN VS. OFFICES OF THE HON. PRESIDENT OF THE
REPUBLIC OF THE PHILIPPINES, HON. SENATE PRESIDENT, HON. SPEAKER OF THE
HOUSE OF REPRESENTATIVES AND HON. SOLICITOR GENERAL, G.R. No. 205043,
EDUARDO B. OLAGUER and the CATHOLIC XYBR APOSTOLATE OF THE PHILIPPINES
VS. DOH SECRETARY ENRIQUE T. ONA, G.R. No. 205478, REYNALDO I. ECHAVEZ,
MD., et al. VS. HON. PACQUITO N. OCHOA, JR., et al., G.R. No. 205491, Spouses
FRANCISCO S. TATAD and MA. FENY C. TATAD, et al. VS. OFFICE OF THE PRESIDENT
OF THE REPUBLIC OF THE PHILIPPINES- SC ENBANC", pursuant to Sections 5, 7 and 13,
Rule 13 of the 1997 Rules of Civil Procedure, as follows:
Copy Furnished by registered mail:.
Counsel for tfle Petitioners in
GR No. 204819
139 Malakas St., Diliman, Quezon City
MCS Noche Law Office
GR No. 204934
91 Melchor St., Loyola Heights, 1108
Quezon City
(/) By depositing a copy on the date and
in the post office indicated below, as
evidenced by the following Registry
Receipt(s) No(s). hereto attached and
indicated after the name(s) of the
addressee(s), and with instructions to the
postmaster to return the mail to the
sender after ten (1 0) days if undelivered.
Quezon City HaiiPost Office
23 April 2013
23 Apri12013
Petitioner-in-Intervention in
GR No. 204934
Suite 1402, 14th Floor, Manila Astral
Errnila, Manila
IVJ.B. IVIAHINAY & ASSOCIATES
GR No. 204957
Diamond St. cor Jade St. Francisca
Village 6
1
h Street, Happy Valley, Cebu City
GR No. 204988
Mandurnol Upper Makasandig,
Cagayan de Oro City
A TTY. EXPEDITO A. BUGARIN, JR.
Banilad, Cebu City
GR No. 205043
Penthouse, Aurora Milestone Tower
1045 Attrora Boulevard, Quezon City
CALLEJA LAW OFFICE
GR No. 205478
Unit 1903-A West Tower
Pasig City
ATTY. ALAN F. PAGUIA
GR No. 205491
101 Mott1er lgnacia St., Barangay
Soutt1 Triangle, Quezon City
1229 Makati City
C!uezon City, for Manila.
23 April 2013.
23 April 2013
23 April 2013
23 April 2013
23 April 2013
Registry Receipt No __ _
23 April 2013
23 April 2013
23 April 2013
23 April 2013
Affiant
AND SWORN to before me this 23 day of April 2013 at
________ l;;d.__C , affiant personally appeared before me and exhibited his Government I.D.
No 6867623 issued at Quezon City on 26 . . I
Doc ,
Page No )U, _, 111
Book No d . riot::Jfj Publ<t. i
___ , .urJii,-llb>C.il uniil31 Decmntrur20i<ll\ f
Series of 20 "13. rUI, I. :fdilloH r lu 01 {/Hl I C!.<ll, :
: ).! ;--; l',h; / 1:! I j
u: ALlutTH::'\" f"Jo, t l'":::tn f
nff4:e J4ilippin:es
nf
<@uel!nn J!R:efrn
afi.
Speaker
16 April 2013
HON. EDCEL C. LAG MAN
First District of Albay
North Wing 411, House of Representatives
Constitution Hills, Quezon City
Dear Hem. Lagman:
1
ANNEX

With the conformity of Solicitor General Francis H. Jardeleza, I hereby
authorize you to appear before the Supreme Court on behalf of the House of
Representatives, which is a respondent in G.R. No. 204933, entitled "Serve
Life Cagayan de Oro City, Inc., et al. vs. Office of the President, Senate of
the Philippines, House of Representatives, et al." and G.R. No. 205003,
entitled "Expedito A. Bugarin
1
Jr. vs. Offices of the Hon. President of the
Republic of the Philippines, Hon. Senate President, I1on. Speaker of the
I-louse of Representatives and Hon. Solicitor General," in collaboration with
the Office of the Solicitor General.
Thank you.
Very truly yours,
Copy l\uui;iled:
Hou. Francis H. Jardeleza
Solicitor Geueral
Otlice of rile Solicitor Geneml
l St.; Legaspi Viilagr;
tvi;'L"Li City
l ANNEX "2'1
Republic of the Philippines
SUPREME COURT
Manila
EN BANC
JAMES M. IMBONG and
lOVELY-ANN C. IMBONG, et
Petitioners
-versus-
HON. PACQUITO N. OCHOA,
JR., et al./
Respondents
x--------------------------------x
ALLIANCE FOR THE FAMILY
FOUNDATION PHILIPPINES,
INC. (ALFI), et al.,
Petitioners
-versus-
Executive Secretary
1
et a I.
1
Respondents
x--------------------------------x
SJS PRESIDENT SAMSON S.
ALCANTARA/
Petitioner -in-Intervention
-versus-
JR., et al.,
Respondents
x--------------------------------x
G.R. No. 204819
G.R. No. 204934
G.R. No. 204934
TASK FORCE FOR FAMILY AND
LIFE VISAYAS, INC. and
VALERIANO S. AVILA,
Petitioners
-versus-
JR., et al.,
Respondents
x - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - x
SERVE LIFE CAGAYAN DE ORO
CITY, INC., et al.,
Petitioners
-versus- .
OFFICE OF THE PRESIDENT,
SENATE OF THE PHILIPPINES,
HOUSE OF
REPRESENTATIVES, et al.,
Respondents
x--------------------------------x
EXPEDITO A. BUGARIN,
Petitioner
-versus-
OFFICES OF THE HON.
PRESIDENT OF THE REPUBLIC
OF THE PHILIPPINES, HON.
SENATE PRESIDENT, HON.
SPEAKER OF THE HOUSE OF
REPRESENTATIVES AND HON.
SOLICITOR GENERAL,
Respondents
x--------------------------------x
EDUARDO B. OLAGUER and
the CATHOLIC XYBR
G.R. No. 204957
G.R. No. 204988
G.R. No. 205003
2
APOSTOLATE
PHILIPPINES,
OF THE
Petitioners
-versus-
DOH SECRETARY ENRIQUE T.
ONA,
Respondent
x - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - x
REYNALDO I. ECHAVEZ, MD.,
et al.,
Petitioners
-versus-
JR., et al.
Respondents
x--------------------------------x
Spouses FRANCISCO S. TATAD
and MA. FENY C. TAT AD, et al.,
Petitioners
-versus-
OFFICE OF THE PRESIDENT
OF THE REPUBLIC OF THE
PHILIPPINES,
Respondent
x--------------------------------x
REPRESENTATIVE EDCEL C.
LAG MAN
Respondent -in-Intervention
x--------------------------------x
G.R. No. 205043
G.R. No. 205478
G.R. No. 205491
3
COMMENT -IN-INTERVENTION
RESPONDENT-IN-INTERVENTION Representative Edcel C.
Lagman, hereinafter referred to as Intervenor Lagman, most
respectfully interposes the instant Comment-in-Intervention in
accordance with the following presentation:
PRELIMINARY STATEMENT
After a 13-year saga spanning five (5) Congresses - from the
11th Congress to the current 15th Congress- the latest versions of the
Reproductive Health Bills (House Bill No. 4244, entitled "An Act
Providing for a Comprehensive Policy on Responsible Parenthood,
Reproductive Health, and Population and Development and For Other
Purposes" in the House of Representatives and Senate Bill No. 2865,
entitled "An Act Providing for a National Policy on Reproductive
Health and Population and Development" in the Senate) had been
finally enacted on 21 December 2012 when President Benigno Aquino
III signed the pertinent enrolled bill as Republic Act No. 10354 or the
''Responsible Parenthood and Reproductive Health Act of 2012
11
,
4
hereinafter referred to as the Reproductive Health Law or the RH
Law.
As expected, like almost all controversial measures, the
constitutionality of the Reproductive Health Law has been challenged
before the Honorable Supreme Court in nine petitions, including one
petition-in-intervention.
The reproductive health advocates and the authors of the
Reproductive Health Law led by Intervenor Lagman anticipated this
eventuality. They have fully prepared to defend and sustain the
constitutionality of the Reproductive Health Law before the Honorable
Supreme Court.
Reproductive Health and Family Planning
are Basic Universal Human Rights
The right to reproductive health and family planning are
inalienable human rights. This inherent truism was affirmed in the
Proclamation of Teheran as the Final Act of the International
Conference on Human Rights in Teheran from 22 April to 13 May
1968 or 45 years ago, to which the Philippines is a signatory.
Paragraph 16 of the Teheran Proclamation unequivocally provides:
5
"The protection of the family and of the
child remains the concern of the international
community. Parents have a basic human right
to determine freely and responsibly the
number and the spacing of their children."
(Emphasis supplied).
The central figure in the Reproductive Health Law is the women
- adolescent girl, teenage mother, multi-parity wife, victim of
maternal mortality and even the tormented woman of a forced
abortion who cannot afford another child.
This brings to fore the Convention on the Elimination of All
Forms of Discrimination Against Women (CEDAW) which was
adopted by the United Nations General Assembly on 18 December
1979 and to which the Philippines is a State Party. It is said that
"among the international human rights treaties, the Convention takes
an important place in bringing the female half of humanity into the
focus of human rights concerns."
Article 12 and Article 16(e) of the Convention are truly
instructive and relevant. Article 12 provides:
"1. States Parties shall take all appropriate
measures to eliminate discrimination against
women in the field of health care in order to
ensure, on a basis of equaUty of men and women,
access to health care services, including those
related to family planning. (Emphasis
supplied).
6
2. Notwithstanding the prov1s1ons of
paragraph I of this article, States Parties shall
ensure to women appropriate services in
connection with pregnancy, confinement and the
post-natal period, granting free services where
necessary, as well as adequate nutrition during
pregnancy and lactation."
Article 16(e) likewise mandates:
"1. States Parties shall take all appropriate
measures to eliminate discrimination against
women in all matters relating to marriage and
family relations and in particular shall ensure, on a
basis of equality of men and women:
XXX XXX XXX
(e) The same rights to decide freely
and responsibly on the number and spacing
of their children and to have access to the
information, education and means to enable
them to exercise these rights." (Emphasis
supplied).
In September 1994, 179 governments, including the
Philippines, adopted the Programme of Action of the International
Conference on Population and Development (ICPD) in Cairo. This is
the bible worldwide on reproductive health and family planning.
Principle 4 of the ICPD Programme provides:
"Advancing gender equality and equity and the
empowerment of women, and the elimination of all
kinds of violence against women, and ensuring
7
women's ability to control their own fertility,
are cornerstones of population and
development- related programmes. The
human rights of women and the girl child are an
inalienable, integral and indivisible part of universal
human rights. The full and equal participation of
women in civil, cultural, economic, political and
social life, at the national, regional and
international levels, and the eradication of all forms
of discrimination on grounds of sex, are priority
objectives of the international community."
Principle 8 provide's:
"Everyone has the right to the enjoyment of the
highest attainable standard of physical and mental
health. States should take all appropriate measures
to ensure, on a basis of equality of men and
women, universal access to health-care services,
including those related to reproductive
health care, which includes family planning
and sexual health. Reproductive health-care
programmes should provide the widest
range of services without any form of
coercion. All couples and individuals have the
basic right to decide freely and responsibly
the number and spacing of their children and
to have the information, education and
means to do so." (Emphasis supplied).
Chapter VII of the ICPD Programme of Action is devoted to
reproductive rights and reproductive health. Among others, it
provides that:
"7.2. Reproductive health is a state of complete
physical, mental . and social well-being and not
merely the absence of disease or infirmity, in all
matters relating to the reproductive system and to
its functions and processes. Reproductive health
therefore implies that people are able to have a
satisfying and safe sex life and that they have the
8
capability to reproduce and the freedom to decide
if, when and how often to do so. Implicit in this
last condition are the right of men and women to
be informed and to have access to safe, effective,
affordable and acceptable methods of family
planning of their choice, as well as other methods
of their choice for regulation of fertility which are
not against the law, and the right of access to
appropriate health-care services that will enable
women to go safely through pregnancy and
childbirth and provide couples with the best
chance of having a healthy infant. In line with the
above definition of reproductive health,
reproductive health care is defined as the
constellation of methods, techniques and services
that contribute to reproductive health and well-
being by preventing and solving reproductive
health problems. It also includes sexual health,
the purpose of which is the enhancement of life
and personal relations, and not merely counselling
and care related to. reproduction and sexually
transmitted diseases."
"7.3. Bearing in mind the above definition,
reproductive rights embrace certain human rights
that are already recognized in national laws,
international human rights documents and other
consensus documents. These rights rest on the
recognition of the basic right of all couples and
individuals to decide freely and responsibly the
number, spacing and timing of their children and
to have the information and means to do so, and
the right to attain the highest standard of sexual
and reproductive. health. It also includes their right
to make decisions concerning reproduction free of
discrimination, coercion and violence, as
expressed in human rights documents. In the
exercise of this right; they should take into
account the needs of their living and future
children and their responsibilities towards the
community. The promotion of the responsible
exercise of these rights for all people should be
the fundamental basis for government- and
policies and programmes in
the area of reproductive health, including family
planning. As part of their commitment, full
9
attention should be given to the promotion of
mutually and equitable gender relations
and particularly to meeting the educational and
service needs of adolescents to enable them to
deal in a positive and responsible way with their
sexuality. Reproductive health eludes many of the
worlds people because of such factors as:
inadequate levels of knowledge about human
sexuality and inappropriate or poor-quality
reproductive health information and services; the
prevalence of high-risk sexual behaviour;
discriminatory social practices; negative attitudes
towards women and girls; and the limited power
many women and girls have over their sexual and
reproductive lives. Adolescents are particularly
vulnerable because of their lack of information and
access to relevant services in most countries.
Older women and men have distinct reproductive
and sexual health issues which are often
inadequately addressed."
XXX XXX XXX
"7 .12. The aim of family-planning programmes
must be to enable couples and individuals to
decide freely and responsibly the number and
spacing of their children and to have the
information and .means to do so and to ensure
informed choices and make available a full range
of safe and effective methods. The success of
population education and family-planning
programmes 1n a variety of settings
demonstrates that informed individuals
everywhere can and will act responsibly in
the light of their own needs and those of
their families and communities. The
principle of informed free choice is essential
to the long-term success of family-planning
programmes. Any form of coercion has no
part to play. In every society there are many
social and economic incentives and disincentives
that affect individual decisions about child-bearing
and family size. Over the past century, many
Governments have experimented with such
schemes, including specific incentives and
10
disincentives, in order to lower or raise fertility.
Most such schemes have had only marginal impact
on fertility and in some cases have been
counterproductive. Governmental goals for family
planning should be defined in terms of unmet
needs for information and services. Demographic
goals, while legitimately the subject of
government development strategies, should not
be imposed on family-planning providers in the
form of targets or quotas for the recruitment of
clients." (Emphasis supplied).
XXX XXX XXX
"7.24. Governments should take appropriate
steps to help women avoid abortion, which
in no case should be promoted as a method
of family planning, and in all cases provide
for the humane treatment and counselling
of women who have had recourse to
abortion." (Emphasis supplied).
A year after ICPD, the Fourth World Conference on Women was
held in Beijing from 4 to 15 September 1995. The Beijing Declaration
and Platform for Action, to which the Philippines is also a signatory,
paralleled and reiterated the ICPD Programme of Action on
reproductive health and family planning.
According to the World Health Organization (WHO):
"The global mandate for sexual and reproductive
health derives from international consensus
agreements such as the Programme of Action of the
International Conference on Population and
Development (ICPD, 1994) and the Platform for
11
Action of the Fourth World Conference on Women
(Beijing 1995). Both consensus documents were
signed by the Government of the Philippines. The
most recent mandate is given by World Health
Assembly Resolution 57.12 which was adopted by
WHO Member States, including the Government of
the Philippines, in May 2004. This Resolution
endorses the strategy entitled, Reproductive health:
a strategy to accelerate progress towards the
attainment of international development goals and
targets."
"The Strategy reaffirms the definition of
reproductive health agreed upon in ICPD and
FWCW. It emphasizes that the various dimensions .
of sexual and reproductive ill-health - maternal and
newborn morbidity and mortality, lack of access to
family planning, unsafe abortion, sexually
transmitted infections and gynaecological
morbidities - account for 20/o of the global burden
of disease for women and 14/o for men."
It is important to underscore that since the Philippines is a
signatory to all the above conventions and covenants, it is duty-
bound to protect, promote and fulfill the Filipinos' right to
reproductive health and family planning. The Reproductive Health
Law is a measure of c9mpliance by the Philippines with its avowed
commitments.
The Philippines is also committed to achieving by 2015 the
Millennium Development Goals, among which are the reduction of
infant mortality (MDG No.4) and the improvement of maternal health
(MDG No. 5), which was amended to include universal access to
12
reproductive health by 2015. The Philippines' performance on
maternal health is dismal with 14 mothers currently dying daily from
complications or causes related to pregnancy and childbirth or 5,110
maternal deaths a year.
The MDG target in maternal mortality rate (MRR) is 52 deaths
per 100,000 live births in 2015 with an escalating MRR, MDG 5 on
irnprovement of maternal health has been identified as the MDG
which the Philippines is least likely to achieve.
The passage of the Reproductive Health Law will help the
Philippines approximate compliance with MDG No. 5 and the other
seven MGDs wherein reproductive health is the common
denominator.
FREEDOM OF INFORMED CHOICE
The hallmark of the Reproductive Health Law is freedom of
informed choice. No beneficiary of reproductive healthcare services
and no acceptor of a legitimate family planning method is a
compelled or coerced adherent
13
Neither the State nor the Church has the authority to compel a
citizen or faithful to a d o p ~ a particular family planning method it
endorses. The option or choice belongs to the concerned woman or
couple.
Thus, Section 3(a) and Section 3(h) of the Guiding Principles
for Implementation of the RH Law unequivocally provide:
"Sec. 3( a) -The right to make free and informed
decisions, which is central to the exercise of any
right, shall not be subjected to any form of
coercion and must be fully guaranteed by the
State, like the right itself."
XXX XXX XXX
"SEC. 3(h) - The State shall respect individuals'
preferences and choice of family planning methods
that are in accordance with their religious
convictions and cultural beliefs, taking into
consideration the State's obligations under various
human rights instruments."
Consequently, an enabling environment shall be created and
assured to allow women and couples to freely choose the method of
family planning from the natural to the modern that they wish to
adopt consistent with their personal needs, individual consciences
and religious beliefs.
The government shall conduct a massive information campaign
on the benefits of family planning without any bias for or agai0st any
14
method. The only limitation is that the entire menu of family planning
methods must be legal, medically-safe, affordable and truly effective.
The government shall afford acceptors access to the family
planning supplies of their choice which shall be given free to the poor
and marginalized.
Sustained information campaign shall be undertaken because
freedom of choice will not be meaningful if there is no prior complete
and accurate information, including the possible side-effects and
failure rates of the various methods of family planning. Thus, Section
3(e) of the RH Law provides:
"SEC. 3(e)- The State shall promote and provide
information and access, without bias, to all methods
of family planning, including effective natural and
modern methods which have been proven medically
safe, legal, non-abortifacient, and effective in
accordance with scientific and evidence-based
medical research standards such as those registered
and approved by the FDA for the poor and
marginalized as identified through the NHTS-PR and
other government measures of identifying
marginalization: Provided, That the State shall also
provide funding support to promote modern natural
methods of family planning, especially the Billings
Ovulation Method, consistent with the needs of
acceptors and their religious convictions."
Corollarily, Section 20 on Public Awareness provides that:
"SEC. 20. Public Awareness. - The DOH and the
LGUs shall initiate and sustain a heightened
nationwide multimedia-campaign to raise the level of
15
public awareness on the protection and promotion of
reproductive health and rights including, but not
limited to, maternal health and nutrition, family
planning and responsible parenthood information
and services, adolescent and youth reproductive
health
1
guidance and counseling and other elements
of reproductive health care under Section 4( q)."
"Education and information materials to be
developed and disseminated for this purpose shall
be reviewed regularly to ensure their effectiveness
and relevance."
It is in this sensitive area of giving factual and truthful
information that the misinformation being peddled by the oppositors
of the Act should be exposed and rebutted, like the following:
1. It is false and malicious to claim that the Reproductive
Health Law legalizes abortion. It does not. The measure repeatedly
provides to the point of superfluity that abortion is illegal and criminal
and is not part of the menu of legally permissible and legally safe
family planning methods. In this regard, the following are the
pertinent provisions of the RH Law:
"SEC. 3 - U) While this Act recognizes that
abortion is illegal and punishable by law, the
government shall ensure that all women needing
care for post-abortive complications and all other
complications arising from pregnancy, labor and
delivery and related issues shall be treated and
counseled in a humane, nonjudgmental and
compassionate manner in accordance with law and
medical ethics;" (Emphasis supplied).
16
"SEC. 4. Definition of Terms. - For the purpose
of this Act, the following terms shall be defined as
follows:
"( q) Reproductive health care refers to the
access to a full range of methods, facilities, services
and supplies that contribute to reproductive health
and well-being by addressing reproductive health-
related problems. It also includes sexual health, the
purpose of which is the enhancement of life and
personal relations. The elements of reproductive
health care include the following:
XXX XXX XXX
(3) Proscription of abortion and management
of abortion complications." (Emphasis supplied).
"SEC. 9. The Philippine National Drug Formulary
System and Family Planning Supplies. - The
National Drug Formulary shall include hormonal
contraceptives, intrauterine devices, injectables and
other safe, legal, non-abortifacient and effective
family planning products and supplies. The
Philippine National Drug Formulary System (PNDFS)
shall be observed in selecting drugs including family
planning supplies that will be included or removed
from the Essential Drugs List (EDL) in accordance
with existing practice and in consultation with
reputable medical associations in the Philippines.
For the purpose of this Act, any product or supply
included or to be included in the EDL must have a
certification from the FDA that said product and
supply is made available on the condition that
it is not to be used as an abortifacient."
2. It is likewise misleading and inaccurate to claim that the use
of contraceptives will eventually lead to the legalization of abortion.
The truth is Catholic and Muslin countries which have liberalized the
17
use of contraceptives still criminalize abortion. Moreover, there is an
inverse correlation between contraceptive use and abortion. The
regular and correct use of contraceptives drastically reduces abortion
rates to the extent of 85/o since unplanned and unwanted
pregnancies, which are the ones usually aborted, are avoided. These
are well-documented by empirical studies conducted by Guttmacher
Institute.
Consequently, women do not have to resort to abortion and the
State finds no need to legalize abortion.
3. It is utterly unchristian and grossly inhuman to deny medical
care and counsel to women suffering from post-abortion
complications on the pretext that this would condone and encourage
abortion.
4. The proposition that the use of modern family planning will
wipe out the Filipino race in a catastrophic demographic winter is a
scare tactic which fails to comprehend the dynamics of population
momentum wherein the country's population will continue to grow
even if the population growth rate is increasingly reduced to below
replacement levels.
18
According to the projections of the National Statistics
Coordination Board, if our Total Fertility Rate (TFR) continues to
decrease by 0. 2 children per woman every five years, replacement
fertility of 2.1 children will be achieved only by 2040. However, the
effects of "population momentum" or the continuous increase in
population will go on for another 60 years by which time the
population of the country would have reached 240 million. In the
case of Thailand, it current!y has what is called ''below-replacement
fertility" for some time now and yet its population continues to grow
because of population momentum.
The dynamics of policymaking is that policies are never cast on
stone. They are flexible and reversible. Given the experiences of
.P
countries like Singapore, South Korea and Japan where there is a
thinning young population and the need to accelerate Population
Growth Rate (PGR), the Philippines can anticipate well in advance
these eventualities without forfeiting the vast opportunity of
economic growth by currently m i t i g a t i n ~ population expansion.
5. Hailing labor migration as the beneficent result of population
power is a misplaced accolade to inordinate fertility. Dollar
remittances from OFWs should not blind us to the incalculable social
and economic costs of labor migration.
19
Moreover, the so-called "population power" often explodes on
our faces as market for labor migration becomes depressed when
economies collapse.
6. The issue on population is not a simple matter of population
density but more importantly, it is a question of sustainable human
development. Concededly, there are still vast unpopulated areas of
the country but these are places hostile to human development
because there are rio infrastructures in place, no schools, no
hospitals, and no visible means of livelihood and employment.
Certainly, we can place the entire world's population of 7 billion
people in an area the size of the State of Texas. But they would end
up eating each other's sewage!
7. It is a myopic view that since contraceptives are available in
the market, there is no need to enact a law on reproductive health
and family planning. This contention overlooks that availability does
not mean access, particularly to those who are uninformed and could
not afford to buy reproductive health supplies. The RH Law is not
limited to contraceptives because it covers a wide range of related
subjects.
20
The RH Law Renders Fealty to
Constitutional Mandates
The salutary constitutional provisions on the right to quality
education (Sec. 1, Article XIV); right to health (Sec. 15, Art. II); right
to a family living wage and income (Sec. 3(2), Art. XV); right to a
balanced and healthful ecology (Sec. 16, Art. II); and the right of
children to proper care and nutrition and protection from all forms of
neglect, abuse, cruelty, exploitation and other conditions prejudicial
to their development, will all be illusory if the government is unable
to promote reprod11ctive health and family planning as indispensable
tools to manage population growth and achieve sustainable human
development.
The Reproductive Health Law accords fealty to these
constitutional mandates.
The RH Law is an Indispensable CompoJlent of an Agenda
on Sustainable Human Development and Poverty Alleviation
The late Rafael Salas, a Filipino and the first Executive Director
of the United Nations Population Fund who served for 20 years,
emphasized that no human development program is bound to
.
succeed if the problem of. population is not simultaneously and
21
positively addressed by government. This statement underscores the
intrinsic interrelationship among population, poverty and sustainable
human development.
An inordinately huge population impacts negatively on all
indicators of human development such as quality education,
adequate medical care, food security, availability of employment,
sufficient mass housing and a healthy ecology.
Invariably, all the more populous countries in the world rank
low in human development. The Philippines, which is the 12th most
populous country in the world with 94 million people, is llih in the
2011 UN-measured Human Development Index released in 2012. The
country went down by an unprecedented 15 ranks from 9ih in the
previous years.
The Reproductive Health Law aims to protect the family from
poverty and want by helping w o m ~ n and couples achieve their
fertility goals, thus making family life more affordable and enabling
parents to invest more on human capital.
Empirical studies consistently document that larger families are
almost invariably poorer than smaller families.
22
Data from the National Statistics Office 1985 to 2000 or a
period of 15 years demonstrate that there is indeed greater incidence
of poverty in larger families. Large families are prone to poverty with
57.3/o of Filipino families with seven children mired in poverty while
only 23.8/o of families having two children live below the poverty
threshold.
What is even more alarming are the results of studies
conducted by the Philippine Institute for Development Studies (PIDS)
which show that large family size is a significant factor in keeping
families poor across generations (Orbeta and Pernia).
According to the UN State of the World Population Report 2002,
"family planning and reproductive health are essential to reducing
poverty." The report declares that "countries that invest in
reproductive health and family planning and in women's development
register lower population growth and faster economic growth."
In a recent study of poverty and its causes in the Philippines,
the Asian Development Bank listed an expanding population as one
of the major causes of poverty in the country.
23
Popular Support for the Reproductive Health Law
Vox o p u l ~ vox Dei (the voice of the people is the voice of God)
and vox populi est suprema lex (the voice of the people is the
supreme law) are truisms most relevant to the RH Law. Consider the
following popular survey results:
96/o of Catholics say it is important to have the ability to control
their fertility and most approve of the use of contraceptives
expressly forbidden by the Church (SWS, July 1991).
Pulse Asia has conducted regular surveys (1995, 2001, 2004, 2007
and 2010) on family planning and the results have consistently
.
revealed that Filipinos believe in the importance of family
planning. Consider the 2007 results:
, 92/o of all Filipinos believe that it is important to have the
ability to control onefs fertility and plan one's family.
, 93/o of all Roman Catholics surveyed said that family planning
is important. This is an even higher percentage than the
national average of 92/o.
24
')i- 89/o of all Filipinos support government funding for modern
methods of family planning.
r 90/o of all Roman Catholics surveyed agreed that government
should allocate funding to modern FP methods. Again, this is an
even higher percentage than the national average of 89/o.
';;- The top three ethnic groups which support public funding for
contraceptives are: Bicolanos (96/o ), Pangasinenses (96/o) and
Kapangpangans (95/o).
'Y 75/o of Filipinos will support candidates who are in favor of a
government budget for family planning.
'r Top three ethnic groups who will support candidates who are in
favor of government budget for family planning are:
Pangasinenses (96/o ), Bicolanos (90/o) and Tagalogs (80/o ).
'r On the question of whether a candidate's support for family
planning determines his/her electoral victory or defeat, 52/o of
Filipinos surveyed say that a pro-family planning agenda will
ensure a candidate's victory compared to the only 6.0/o who
25 .
say that it would mean his or her defeat. 41 /o say that it will
have no effect in a candidate's potential victory or defeat.
'r 76/o of Filipinos consider it important that a candidate includes
family planning in his or her program of action.
,.- 77/o of Roman Catholics surveyed say that it is important that
family planning be included in a candidate's program of action.
Again, this is even higher than the national average of 76/o.
When the reproductive health bills were pending in the
Congress, it had continuing multi-sectoral support from the following:
1. Inter-faith Partnership composed of Iglesia ni Cristo, Jesus is
Lord Movement, majority of the Protestant churches and
Muslim leaders;
2. Employers' groups like the Employers Confederation of the
Philippines (ECOP), Financial Executives Institute of the
Philippines (FINEX), Makati Business Club (MBC),
Management Association of the Philippines (MAP) and the
Philippine Chamber of Commerce and Industry (PCCI);
26
3. Labor unions like the Bukluran ng Manggagawang Pilipino
(BMP), Partido ng Manggagagwa (PM) and Trade Union
Congress of the Philippines (TUCP);
4. The academe like the UP Economics professors, UP Manila
Center for Gender and Development Studies; UP Diliman
College of Social Work and Community Development; UP
Diliman Center for Women's Studies; Ateneo de Manila
University Professors and De La Salle University Faculty
Members;
s. Government agencies like the Department of Social Welfare
and Development (DSWD); the National Economic
Development Authority (NEDA); the Department of Health
(DOH); the Department of Labor and Employment (DOLE)
and the Department of Justice (DOJ), among others;
6. Scientists from the National Academy of Science and
Technology;
7. Medical organizations such as the Philippine Obstetrical and
Gynecological Society (POGS) and the Philippine Society of
Reproductive Endocrinology and Infertility (PSREI);
27
8. Human rights groups like the Cordillera Human Rights
Alliance; Amnesty International and Women's Legal Bureau;
9. Multi-sectoral organizations like the Welga ng Kababaihan;
Samahan ng Mamamayan - Zone One Tondo Organization
and Damayan ng Maralitang Pilipino (DAMPA)
10. The vast NGO community constituting the Reproductive
Health Advocacy Network (RHAN), which includes the
Philippine Legislators Committee on Population and
Development (PLCPD), The Forum for Family Planning and
Development (the FORUM), Likhaan Center for Women's
Health, Inc. (Likhaan), Democratic Socialist Women of the
Philippines (DSWP), Reproductive Health, Rights and Ethics
Center for Studies and Training (Reprocen), Catholics for
Reproductive Health (C4RH) and Family Planning
Organization of the Philippines (FPOP), among others;
11. Civil Society Groups like the Philippine NGO Council on
Population, Health and Welfare (PNGOC); Action for Health
Initiatives, Inc. (ACHIEVE); Filipino Free Thinkers (FF); and
WomenHealth Philippi.nes;
28
12. Tri-media practitioners and social media enthusiasts who
have been enduring partners in the RH campaign.
ARGUMENTS OF THE PETITIONERS
1. In a virtual compendium of the usual anti-RH homilies
and tirades, the petitioners, either collectively or separately, posit the
following arguments assailing the constitutionality of the
Reproductive Health Law:
(a) The Reproductive Health Law violates the "right to life of
the unborn" as enshrined in Section 12 of Article II of the
Constitution;
(b) Contraceptives are abortifacients;
(c) The Reproductive Health Law infringes on the people's
"right to health" which is constitutionally guaranteed;
(d) The RH Law is offensive to the freedom of religion; and
29
(e) The RH Law supplants the natural and primary right of
parents to develop their children's moral character by
prescribing reproductive health education for adolescents.
ARGUMENTS SUSTAINING THE CONSTITUTIONALITY
OF THE REPRODUCTIVE HEALTH LAW
I. THE RH LAW PROTECTS AND
RESPECTS THE LIFE OF THE
UNBORN FROM CONCEPTION.
II. CONTRACEPTION
ABORTION
CONTRACEPTIVES
ABORTIFACIENTS.
IS NOT
AND
ARE NOT
III. RH LAW PROTECTS AND
PROMOTES THE PEOPLE'S
RIGHT TO HEALTH.
IV. THE RH LAW RESPECTS AND
UPHOLDS THE FREEDOM OF
RELIGION AND THE
HALLMARK OF THE RH LAW IS
FREEDOM OF INFORMED
CHOICE.
V. THE RH LAW COMPLIES WITH
THE CONSTITUTIONAL
MANDATE THAT THE
GOVERNMENT SHALL
SUPPORT THE RIGHT AND
DUTY OF PARENTS OF
DEVELOPING THE MORAL
CHARACTER OF THE YOUTH
BY PRESCRIBING
REPRODUCTIVE HEALTH
EDUCATION FOR
ADOLESCENTS.
i\.
30
DISCUSSiON
I. THE RH LAW PROTECTS
AND RESPECTS THE LIFE OF
THE UNBORN FROM
CONCEPTION.
1. The very constitutional provision invoked by the
petitioners, which is Section 12 of Article II of the Constitution,
provides that the "State shall equally protect the life of the mother
and the unborn from (Emphasis supplied). Clearly,
before the onset of conception, there is no unborn whose life shall be
protected. Conception has been defined by medical authorities as the
implantation of the fertilized ovum in the woman's uterus. Conception
is synonymous with pregnancy. It is only at the start of conception
that pregnancy can be detected.
2. It must be underscored that the Constitution provides the
protection of the unborn from conception, not from fertilization. This
is a clear recognition that ( 1) the fertilized ovum cannot have a viable
existence without its implanting in the uterine lining; (2)
consequently, there is yet no human life to protect in a fertilized
ovum; and (3) fertilization is not synonymous with conception.
3. Verily, in the earlier stages of the reproductive process like
31
ovulation, copulation and fertilization, there is still no unborn whose
life has to be protected.
4. Nowhere in the proceedings of the Constitutional
Commission is it on record that the Commissioners had a collective
decision or determination that fertilization is synonymous with
conception.
5. On the contrary, the genesis of Section 12 of Article II of
the 1987 Constitution started with the proposal to include in Section
1 of the Bill of Rights the provision that the "right to life extends to
the fertilized ovum." This proposal was not constitutionalized. It was
rejected in favor of the present provision which guarantees the life of
the unborn from conception, not before conception where there is no
life yet to safeguard. It is the unborn in the mother's womb
upon conception which is constitutionally guaranteed
protection.
6. It is a gynecological and medical truism that not all
fertilization result in conception. A range of 40/o to 70/o of fertilized
ova are naturally lost before and after implantation. Indeed,
fertilization and conception are different phases of the reproductive
process. In fact, conception starts days or even more than a week
32
after fertilization.
7. After the proposal to include in the Bill of Rights a
provision that "The right to life extends to the fertilized ovum" was
not carried, another formulation was included in Article II of the
Declaration of Principles which originally read: "The State shall
protect human life from the moment of conception."
8. It is important to note that the foregoing new formulation
admitted that the protection of human life begins "from the moment
of conception", not anymore from the fertilization of the ovum.
9. As finally adopted, Section 12 of Article II has been
reformulated as it now appears in the Constitution, reading \\the State
shall equally protect the life of the mother and the unborn from
conception." The voting was 33 in favor; 3 against; and 4
abstentions.
10. There were two amendments incorporated in the final
version of the subject provision: (1) the phrase "the moment of"
preceding "conception" was deleted; and (2) the phrase "the life of
the mother" was included. These two amendments are very
significant:
33
a) The deletion of the phases "the moment of"
was the result of the Commissioners'
uncertainty as to the precise beginning of
conception, which is the domain of medical
science.
b) Equal protection of the life of the mother and
the life of the unborn is mandated. In fact,
when both the lives of the mother and the
unborn are imperiled, the invariable option is to
save the life of the mother if both lives cannot
be saved. The doctor's primary obligation is to
the mother because it is she who is the patient.
The importance of the second amendment
which included the protection of the "life of the
mother" is lost because of the undue emphasis
on protecting the life of the unborn.
11. The international scientific community and numerous
medical dictionaries and textbooks define the beginning of pr.egnancy
or conception as the moment the fertilized ovum attaches itself to the
34
lining of the uterus. Pregnancy, therefore, starts at least nearly a
week after fertilization.
12. The American College of Obstetricians and Gynecologists
defines conception as "the implantation of the blastocyst. It is not
synonymous with fertilization." (Emphasis supplied). The
National Institute of Health/Food and Drug Administration states that
"Pregnancy encompasses the period of time from confirmation of
implantation until expulsion or extraction of the fetus."
13. Verily, the fertilized egg has no sustainable viability
outside of the uterine wall. It has to implant in the uterine wall to
have sustainable life and for gestation to progress or for pregnancy to
begin. This is the reason why the fertilized egg in the Petri dish, like
in vitro fertilization, has to be implanted subsequently in the woman's
uterus in order for it to develop into a fetus.
14. In fine, it is the fertilized ovum which has implanted in
the woman's uterus or the fetus which has the human life to protect,
not the fertilized ovum travelling in the fallopian tube before
i m pia ntation.
35
15. The explicit intention of the framers of the 1987
Constitution in protecting the life of the unborn from conception is to
prevent the Congress and the Supreme Court from legalizing
abortion. The RH law does not legalize abortion. In fact, it
acknowledges that abortion is illegal and punishable and is not a
family planning option or method.
1.6. This clear intent is articulated in the proceedings of the
Constitutional Commission of 1986. Thus, Commissioner Bernardo
Villegas, the principal proponent of the protection of the unborn from
conception, explained:
"The intention ... is to make sure
that there would be no pro-abortion
laws ever passed by Congress or any
pro-abortion decision passed by the
Supren1e Court." (Emphasis supplied).
17. Of the same import is the following statement of
Commissioner Felicitas Aquino:
"Would the deletion of the phrase
'from the moment of conception'
legalize abortion? We do not, one bit,
intend to give statutory fiat to the
legalization of abortion by deleting 'the
moment of conception."' (Emphasis
supplied).
36
18. The intention to outlaw abortion was reiterated by
Commissioner Villegas upon interpellation by Commissioner Suarez:
"MR. SUAREZ: So, principally
and exclusively, if I may say so, what
the Commissioner has in mind is only an
act outlawing abortion.
MR. VILLEGAS: Exactly, Madam
President.
MR. SUAREZ: So that is
the real thrust and meaning of this
particular provision?
MR. VILLEGAS: That is right."
19. The RH Law to an indubitable fealty to the
Constitution. It does not legalize abortion. In fact, it is anti-abortion.
As shown in the preceding Preliminary Statement, the RH Law
unequivocally provides that abortion is illegal and is punishable by
law.
20. Since outlawing abortion is the principal objective of the
subject constitutional provision, then it is appropriate to revisit the
medical and legal definitions of abortion to place the RH Law within
context of the constitutional injunction against abortion.
21. The International Federation of Gynecology and
37
'.
Obstetrics (FIGO) defines abortion as the "termination of pregnancy
after implantation and before the conceptus has become
independently viable." (Emphasis supplied).
22. The Philippine Obstetrics and Gynecology Society (POGS)
defines abortion as \\the expulsion of a non-viable fetus on or before
the 20th week of gestation. The fetus is the human embryo from the
end of the second month of gestation until birth."
23. The legal definition of abortion parallels the medical
definition. Black's Law dictionary (tfh ed./ 1990) defines abortion as
the "spontaneous or artificially induced expulsion of an embryo or
fetus." Similarly, the Philippine Legal Encyclopedia (Sibal, Jose
Agaton R., 1995) defines abortion as the "premature expulsion of the
foetus of a pregnant woman."
24. Both legal and medical definitions refer to the expulsion
of the embryo or fetus, not of a fertilized ovum.
25. The medical and legal definitions of abortion denote that
abortion only happens after the onset of conception, not after
fertilization pending implantation of the fertilized ovum.
38
26. This manifestly shows that fertilization is not equitable
with conception.
II. CONTRACEPTION IS NOT
ABORTION AND
CONTRACEPTIVES ARE NOT
ABORTIFACIENTS.
27. There is a whale of a difference between contraception
and abortion. Contraception prevents fertilization, while abortion pre-
terminates conception or pregnancy.
28. It is in the reproductive phase before conception where
the principal mechanism of contraceptives works either to prevent
ovulation or prevent the sperm from fertilizing the egg.
29. In either case, the prime purpose is to prevent
fertilization. If a woman does not ovulate, there is no egg produced
to be fertilized. And if perchance, ovulation ensues, the sperm is
weakened or incapacitated to fertilize the egg. In either case, no
fertilized ovum is produced.
30. Consequently, contraceptives are not abortifacients
39
because they prevent fertilization, and if there is no fertilization, then
there is no fertilized ovum, thus foreclosing conception. This. is the
reason for the nomenclature "contraceptives" or contra conception.
31. Even the Church endorsed natural or traditional method
of family planning of periodic abstinence from mating during a
woman's fertile period is verily a form of contraception because its
purpose is to prevent pregnancy or conception. Likewise, the Church-
favored modern natural methods like the billings method is also
contraception. As far as the purpose is concerned, there is no
distinction between the traditional and modern methods of
contraception. The difference is in their varying efficacy and
convenience.
32. Neither the Constitution nor any statute bans
contraceptives as illegal including the modern or artificial ones. This
is so because all empirical studies document that contraceptives are
not abortifacients.
33. The UN includes contraceptives as part of the WHO Model
List of Essential Medicines Formulary of prescribed drugs and
medicines. In the Philippines, the Food and Drugs Administration
(FDA) approves the sale, distribution and use of contraceptives like
. 40
pills, injectables, IUDs and condoms.
34. In fact, there has been no test case where a couple or a
woman who uses contraceptives or a physician who prescribes
contraceptives has been charged with abortion simply because
contraceptives are not abortifacients.
35. To reiterate, the principal purpose of pills and injectables
is to prevent a woman from ovulation or producing eggs. If a woman
does not ovulate, there is no egg to be fertilized, no conception will
set in and no fetus is formed to be aborted.
36. The principal purpose of IUDs and condoms is to prevent
the sperm form fertilizing the egg and thus effectively prevent
pregnancy or conception.
37. However, if contraception fails and conception sets in,
there should be no human intervention to terminate the pregnancy or
expel the fetus because this is already abortion which is illegal and
criminal.
38. The RH Law even provides that contraceptives must not
prevent the implantation of the fertilized ovum in the woman's uterus
41
as determined by FDA.
39. This provision was included in the law to assure critics
that the present generation of contraceptives does not interfere in
the implantation of the fertilized ovum.
40. Experts and UN agencies are unanimous in declaring that
the alleged third and secondary action of contraceptives to
purportedly prevent the implantation of a fertilized ovum is a mere
commercial claim of manufacturers devoid of any empirical and
scientific authentication, to wit:
(a) The World Health Organization (WHO), represented by
Dr. Soe Nyunt-U, WHO country representative, in a reply dated 06
June 2011 to the query of herein respondent-movant, declared that:
"To date, there is no scientific evidence supporting the
contention that hormonal contraceptives and IUD prevent
the implantation of the fertilized ovum." (Emphasis supplied).
(b) As early as 07 November 2006, the
UNDP/UNFPA/WHO/World Bank Special Program of Research
Development and Research Training in Human Reproduction (HRP)
submitted to the House of Representatives' Committee on Revision of
42
Laws an Expert Opinion on House Bill No. 4643 on abortive
substances and devices in the Philippines declaring that
contraceptives are not abortifacients and the alleged third mechanism
of action of contraceptives has no empirical basis, to wit:
"Combined Hormonal Methods (oral
contraceptives and Evra patch): There
has been a growing body of evidence for
more than four decades indicating that
administration of combined oral
contraceptives (COC) inhibits follicular
development and ovulation, and that this is
their primary mechanism of action (Mishell et
al. 1977; Killick et al. 1987; Rivera et al.
1999). They also affect cervical mucus,
making it thicker and more difficult for sperm
to penetrate. This effect may also contribute
to their high efficacy (Rivera et al. 1999).
Although it is known that there are
changes in the endometrium during
combined oral contraceptive (COC) use,
no evidence to date has supported the
hypothesis that these changes lead to
disruption of implantation. Given the high
efficacy of COCs in preventing ovulation, it is
very unlikely that 'interference with
implantation' is a 'primary mechanism' of
contraceptive action.
The same mechanism of action also
applies to the Evra patch." (Emphasis
supplied).
(c) The foregoing declaration was reiterated by the WHO in a
Position Paper dated 27 October 2010 on Senate Bill 2378 (RH bill)
upon request by the Senate Committee on Health and Demography.
43
(d) No less than the American Association of Pro-Life
Obstetricians and Gynecologists, a Christian medical association, has
also debunked the third and secondary mechanism of action of
contraceptives in a paper entitled "Hormone Contraceptives
Controversies and Clarifications". They declared that:
"An extensive review of pertinent
scientific writings indicates that there is
no credible evidence to validate a
mechanism of pre-implantation abortion
as a part of the action of hormone
contraceptives. On the contrary, the
existing evidence indicates that 'on pill'
conceptions are handled by the reproductive
system with the same results seen with 'off
pill' conceptions, with the exception of
increased ectopic rates seen with POPs and
Norpla nt. II
XXX XXX XXX
"Given the above, there is no evidence
that shows that the endometrial
changes. produced by COCs contribute to
failure of implantation of conceptions,
nor is there evidence that COCs cause an
increased per pregnancy ratio of ectopics. II
XXX XXX XXX
"We have done our best to evaluate the
current literature on the topic, and to present
it fairly for consideration by the reader. We do
not find substantive evidence that hormone
contraceptives include an abortifacient
44
mechanism of action. We recognize that
equally spiritual and honest men and women
may consider the same facts, but come to
differing conclusions on this matter. For the
follower of Jesus, the decision on whether or
not to use or prescribe hormone
contraceptives is a spiritual as well as a
medical matter. The principles of how to
handle a situation among Christian Believers
on a very vital subject in dispute is directly
addressed in Romans chapter 14 as an issue of
individual conscience and responsibility before
the Master.
"Many factors play a part in how a family
plans and spaces their children. It is not the
purpose of this paper to promote nor to
oppose hormone contraception. However, if a
family, weighing all the factors affecting their
own circumstances, decides to use this
modality, we are confident that they are
not using an abortifacient.
"This paper is not meant to be the 'final word'
on this issue. If scientific study should validate
that a hormone contraceptive agent is partly
abortifacient in its action, we would oppose
that agent just as we oppose elective medical
and surgical abortions. We must constantly
examine valid data as it becomes available in
our effort -to discern what are appropriate
methods of family planning to be used or
prescribed by those who know that human
life begins at the time of conception."
(e) The following summary of medical evidence against
claims that hormonal contraceptives and IUDs are abortifacients, in
their third action of mechanism by preventing the implantation of a
fertilized ovum is truly instructive:
45
11
A. For both - A fertilized egg can
implant outside the uterus, on sites
without an endometrium at all, much
more inhospitable than the 'thin'
endometrium that anti-contraceptive
groups claim are causing abortions.
These are called ectopic pregnancies, and are
well-known and observed phenomena. In
contrast, the theory that hormonal
contraceptives and IUDs can make the
endometrium hostile to implantation, though
very old, are not backed up by observation
and empirical evidence.
B. For hormonal contraceptives - The
endometrium relies on hormones produced
by the process of ovulation in order to
thicken and develop. As a consequence of
preventing ovulation, the endometrium does
not develop. Without ovulation, there's no
fertilized egg to stop from implanting.
Therefore, hormonal contraceptives
effect on the endometrium has no
contraceptive impact or value. If the
contraceptive fails in blocking sperm
penetration of the cervical mucus and fails as
well in preventing ovulation, then fertilization,
implantation and pregnancy can and does
occur.
C For IUDs - Many experiments have
unequivocally demonstrated that the
IUD does not act by blocking
implantation. The World Health
Organization supports this conclusion."
41. In the event that subsequent medical studies and empirical
researches would ascertain that contraceptives have the third action
of mechanism of preventing the fertilized ovum from implanting in
46
the uterine lining, and the same is determined by FDA, then the
pertinent provision of t h ~ RH Law outlawing contraceptives which
obstruct the implantation of the fertilized ovum would adequately
answer this eventuality. Thus, the second paragraph of Section 2 (d)
on Declaration of Policy unequivocally provides:
"The State likewise guarantees universal
access to medically-safe, non-abortifacient,
effective, legal, affordable, and quality
reproductive health care services, methods,
devices, supplies which do not prevent the
implantation of a fertilized ovum as
determined by the Food and Drug
Adn1inistration (FDA)." (Emphasis
supplied).
42. Likewise, under Section 4(a) on Definition of Terms, it is
provided that:
"Abortifacient refers to any drug or
device that induces abortion or the
destruction of a fetus inside the mother's
womb or the prevention of the fertilized
ovum to reach and be implanted in the
mother's womb upon determination of
the FDA." (Emphasis supplied).
43. To recap, medical authorities and researches for the past
several decades are of the expert opinion that contraceptives are not
abortifacients because their principal mechanism of action is either to
prevent ovulation or prevent the fertilization of the ovum, in which
case no fertilized ovum is formed for implantation in the uterus.
However, if contraception fails and a fertilized ovum is formed, and it
47
is subsequently ascertained that contraceptives prevent the
implantation of the fertilized ovum, then under the RH Law, the FDA
can determine such secondary action as abortive.
lll. RH LAW PROTECTS AND
PROMOTES THE PEOPlE'S
RIGHT TO HEALTH.
44. Far from infringing the people's "right to health", the RH
law promotes, protects and enhances the right to health, particularly
of mothers and infants because the promotion of reproductive health
and family planning will considerably decrease maternal and infant
mortality rates since high-risk, unwanted and unintended pregnancies
are avoided.
45. Moreover, the promotion of reproductive health and
family planning would assure the birth of healthy infants and
empower parents to give fewer children proper sustenance, health
care and education.
46. The so-called risks of side effects of contraceptives are
not more than those of ordinary drugs and medicines.
47. While there may be risks in contraceptive use just like in
48
other drugs and medicines, risk does not mean actual affliction.
48. The much propagandized carcinogenic risk of
contraceptive use by "pro-lifers" is more of a scare rhetoric than
genuine concern.
49. Paraphrasing the American Association of Pro-Life
Obstetricians and Gynecologists, the mechanism of action of
hormone contraceptives and also their possible adverse side effects
cannot be "illuminated by rhetoric" because "how a medication works
is a scientific question."
50. The following are relevant excerpts from Dr. Esperanza I.
Cabral's comments entitled "Half-truth is a Whole Lie" on the veracity
of reports that certain contraceptives are carcinogenic and hazardous
to women's health (House Resolution No. 491):
a. "Even as the IARC (International
Agency for Research on Cancer of the WHO)
categorizes a certain substance as
carcinogenic, its mother agency, the WHO,
may decide, as indeed it has, that the
substance is beneficial enough to be included
in its Model List of Essential Drugs. This is the
case with oral contraceptives."
49
b. "Several WHO Committees work on
creating evidence-based family planning
guidelines and on keeping them up-to-date on
a continuous basis. They regularly review the
safety of COCs and assess the balance of risks
and benefits of COC use and they have
determined that for most healthy women, the
health benefits clearly exceed the health
risks."
c. "The Women's Contraceptive and
Reproductive Experiences (Women's CARE)
study examined the use of OCs (oral
contraceptives) as a risk factor for breast
cancer in women ages 35 to 64. Researchers
interviewed 4,575 women who were
diagnosed with breast cancer between 1994
and 1998, and 4,682 women who did not
have breast cancer. Investigators collected
detailed information about the participants'
use of OCs, reproductive history, health, and
family history. The results, which were
published in 2002, indicated that current
or former use of OCs did not
significantly increase the risk of breast
cancer."
d. "OCs did not increase the risk of liver
cancer in Asian and African women, who are
considered high risk for this disease.
Researchers believe this is because other risk
factors, such as hepatitis infection, outweigh
the effect of OCs."
e. "Studies have consistently shown
that using OCs reduces the risk of
ovarian cancer. In a 1992 analysis of 20
studies of OC use and ovarian cancer,
researchers from Harvard Medical School
found that the risk of ovarian cancer
decreased with increasing duration of OC use.
Results showed a 10 to 12 percent decrease
50
in risk after 1 year of use, and approximately
a 50 percent decrease after 5 years of use."
f. "The use of OCs has been shown to
significantly reduce the risk of
endometrial cancer. This protective effect
increases with the length of time OCs are
used, and continues for many years after a
woman stops using OCs. II
g. "In sum, contraceptives are just
like any other form of medical
treatment. There are many forms available,
and none are perfect. They vary as to
effectiveness, safety and convenience and
each has its own advantages and
disadvantages. II
h. "All active drugs, including
contraceptives, can cause some adverse
effects in some users, and if safety were
understood as the total absence of
adverse effects, then no drug could be
called 'safe.' Safety of a drug, in real world
terms, is conceived as a favourable ratio of
benefits to risks for the population of users of
the drug as a whole. In deciding to allow
or prohibit the use a drug or device,
contraceptive or not, the predictable
benefits of use must be determined and
weighed against the potential risks."
i. "New data is constantly being produced
in medical science. The quality of the
evidence generated varies so much that a
new branch of learning termed critical
appraisal of medical literature has evolved. It
is understandable that those who are not
practiced in this discipline of rigorous analysis
51
and evaluation of research results may make
a mistake in interpreting data."
j. "Thus this work is best left to the
appropriate expert executive
department of government, in this case,
the Department of Health and its
agency, the Food and Drug
Administration and their expert
consultants and personnel. They should
be entrusted with the responsibility of
permitting and regulating the public use of a
drug or device and given the space to
perform their functions without
interference from special interest groups
and their lobbyists." (Emphasis supplied).
IV. THE RH LAW RESPECTS
AND UPHOLDS THE FREEDOM
OF RELIGION AND THE
HALLMARK Of THE RH LAW IS
FREEDOM OF INFORMED
CHOICE.
51. The accusation that the RH law is offensive to religious
freedom is a patent aberration. The RH Law is replete with provisions
upholding the freedom of religion and respecting religious
convictions. The guarantee of freedom of informed choice, which is
tile hallmark of the RH Law, is an assurance that no one would be
compelled to violate the tenets of his religion or defy his religious
convictions against his free will and own discernment of his faith.
52
52. The option to be a beneficiary of reproductive healthcare
services and be an acceptor of a particular family planning method is
solely the decision of a couple or woman with due regard to one's
religious beliefs and convictions. Good conscience is the anchor
.
of one's choice. As the professors of the Ateneo de Manila
University declared, Catholics can use contraceptives in good
conscience.
53. It is a grossly mistaken view that the government under
the RH Law imposes contraceptive use and family planning on
couples and women by invading the privacy of their bedrooms.
54. There is no such imposition or intrusion because the heart
and soul of the Reproductive Health Law is freedom of informed
choice.
V. THE RH lAW COMPLIES
WITH THE CONSTITUTIONAL
MANDATE THAT THE
GOVERNMENT SHALL
SUPPORT THE RIGHT AND
DUTY OF PARENTS OF
DEVELOPING THE MORAL
CHARACTER OF THE YOUTH
BY PRESCRIBING
REPRODUCTIVE HEALTH
EDUCATION FOR
ADOLESCENTS.
53
55. Section 12 of. Article II is among the 22 provisions
constituting the State Policies or a "Bill of State Obligations" as
distinguished from the Bill of Rights as found in Article III.
Accordingly, the last sentence of Sec. 12 provides: "The natural and
primary right and duty of parents in the rearing of the youth for civic
efficiency and development of moral character shall receive the
support of the Government." (Emphasis supplied).
56. More than a recognition or grant of a right, this provision
is an imposition of an obligation upon the State. Accordingly, the
operative phrase in this provision is "shall receive the support of the
Government."
57. The prescription of a mandatory age and development-
appropriate reproductive health education for adolescents enrolled in
elementary and secondary schools is not an abridgement of the role
of parents in the development of the moral character of their
children. It is a compliance with the bounden duty of Government to
support said parental role.
58. This prescription on RH education assumes more
relevance when we consider that the majority of parents default in
54
teaching their children proper sexual values because of the prevailing
taboo on conversation about sex in Filipino homes.
59. Section 14 of the RH law is no different from the
constitutional obligation of the State "to establish, maintain and
support a complete, adequate and integrated system of education
relevant to the needs .of the people and society" (Sec. 2[1] of Art.
XIV), which is not an impairment of the parent's right and duty in the
rearing of the youth. It is supportive ~ n d co1nplementary.
60. Similarly, the Constitution unequivocally provides that
"Without limiting the natural right of parents to rear their children,
elementary education is compulsory for all children of school age."
(Sec. 2[2] of Art. XIV). Clearly, no less than the Constitution
mandates compulsory elementary education without
violating parental right in the rearing of the youth. The same
standard applies to the teaching of reproductive health to
adolescents.
61. It is a grotesque argument that reproductive health
education for adolescents will create a breed of sex maniacs and
promiscuous youth. This baseless apprehension is debunked by
empirical studies of the United Nations and other progressive
55
countries which document the following beneficent effects of
reproductive health education among the young:
(a) Inculcation of correct and relevant sexual values and
norms in the young which disabuses their minds of
preconceived myths on sex and responsibly addresses
their curiosity so much so that experimenting is foreclosed;
(b) Initiation into sexual activity is delayed;
(c) Multiple sexual partners is avoided;
(d) Abstinence before marriage is encouraged; and
(e) Transmittal of HIV-AIDS and sexually transmitted diseases
is prevented.
SUMMATION
Aside from being constitutional, popularly-endorsed, healthfully
beneficial and compliant with the Philippines' international
commitment on promotion and protection of reproductive rights and
family planning, the Reproductive Health Law is an indispensible
measure for poverty alleviation and the attainment of sustainable
human development.
56
PRAYER
ACCORDINGLY, it is respectfully prayed that the Honorable
Supreme Court admits the instant Comment-in-Intervention and
upholds the constitutionality of Republic Act No. 10354, entitled "An
Act Providing for a National Policy on Responsible Parenthood and
Reproductive Health".
Quezon City, for Manila
24 April 2013

EDCEL C. LAGMAN
Member, House of Representatives
Roll of Attorneys No. 21381
PTR No. 8189823; 04-16-2013 (Quezon Oty)
IBP No. 923026 (CALMANA)
lagmanedcel@yahoo.com
Mobile No. 0916-6406737
EXPLANATION
This Comment-in-Intervention is filed personally with the
Honorable Supreme Court and copies thereof served on the parties,
through counsel, by registered mail because of personnel constraints.
57
Copy furnished:
GR No. 204819
139 Malakas St., Diliman, Quezon City
MCS Noche Law Office
GR No. 204934
" 91 Melchor St., Loyola Heights, 1108
Quezon City
Petitioner -in-In tetven tion in
GR No. 204934
Suite 1402, 14th Floor, Manila Astral
Ermita, Manila
M.B. MAHINAY & ASSOCIATES
GR No. 204957
Diamond St. cor. Jade St. Francisca
Village 6th Street, Happy Valley, Cebu City
GR No. 204988
Mandumol Upper Makasandig,
Cagayan de Oro City
ATTY. EXPEDITO A. BUGARIN, JR.
Banilad, Cebu City
GR No. 205043
Penthouse, Aurora Milestone Tower
1045 Aurora Boulevard, Quezon City
CALLEJA LAW OFFICE
GR No. 205478
Unit 1903-A West Tower
Pasig City
24 April 2013
24 April 2013
24 April 2013
24 April 2013
24 April 2013
24 April 2013
24 April 2013
24 April 2013
58
AITY. ALAN F. PAGUIA
GR No. 205491
101 Mother Ignacia St., Barangay
South Triangle, Quezon City
1229 Makati City
24 April 2013
Registry Receipt No. ---
24 April 2013
59

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