Special Civil Actions Initiated by Complaint:

Interpleader (Rule 62)

RCBC vs. Metro Container Corp. (GR 127913)

It should be remembered that an action of interpleader is afforded to protect a person not against
double liability but against double vexation in respect of one liability. It requires, as an
indespensable requisite, that conflicting claims upon the same subject matter are or may be made
against the plaintiff-in-interpleader who claims no interest whatever in the subject matter or an
interest which in whole or in part is not disputed by the claimants. The decision in Civil Case No.
6202 resolved the conflicting claims insofar as payment of rentals was concerned.

Ocampo vs. Tirona (GR 147812)

An action for interpleader is proper when the lessee does not know the person to whom to pay
rentals due to conflicting claims on the property.

Maglente vs. Hon. Baltazar-Padilla (GR 148182)

Petitioners argument that the trial courts writ of execution in the interpleader case carried with it
the corollary right to a writ of possession is without merit. A writ of possession complements the
writ of execution only when the right of possession or ownership has been validly determined in
a case directly relating to either. The interpleader case obviously did not delve into that issue.

Ramos vs. Ramos (GR 144294)

The Complaint filed by respondents with the RTC called for an interpleader to determine the
ownership of the real property in question. Specifically, it forced persons claiming an interest in
the land to settle the dispute among themselves as to which of them owned the property.
Essentially, it sought to resolve the ownership of the land and was not directed against the
personal liability of any particular person. It was therefore a real action, because it affected title
to or possession of real property. As such, the Complaint was brought against the deceased
registered co-owners: Narcisa, Mario, Paulino and Antonio Chanliongco, as represented by their
respective estates.

Wack-Wack Golf and Country Club vs. Won

Facts: Wack Wack Golf and Country Club filed a complaint for interpleader against Won and
Tan who both claim ownership over membership fee certificate 201. Won claims its ownership
stemming from a decision rendered in Civil Case 26044 entitled "Lee E. Won alias Ramon Lee
vs. Wack Wack Golf & Country Club, Inc." Meanwhile, Tan claims ownership from the
assignment made by the alleged true owner of the same certificate. The trial court dismissed the
complaint on the ground of res judicata by reason of the previous civil case that issued Won the
right to the certificate. Hence, the appeal.

Issue: Was the remedy of interpleader proper and timely?

Held: There is no question that the subject matter of the present controversy, i.e., the
membership fee certificate 201, is proper for an interpleader suit. However, the Corporation may
not properly invoke the remedy of interpleader.

It is the general rule that before a person will be deemed to be in a position to ask for an order of
intrepleader, he must be prepared to show, among other prerequisites, that he has not become
independently liable to any of the claimants. Indeed, if a stakeholder defends a suit filed by one
of the adverse claimants and allows said suit to proceed to final judgment against him, he cannot
later on have that part of the litigation repeated in an interpleader suit.

In the case at hand, the Corporation allowed civil case 26044 to proceed to final judgment. It was
aware of the conflicting claims of the appellees with respect to the membership fee certificate
201 long before it filed the present interpleader suit. Yet it did not interplead Tan. It preferred to
proceed with the litigation and to defend itself therein. As a matter of fact, final judgment was
rendered against it and said judgment has already been executed. It is therefore too late for it to
invoke the remedy of interpleader

To now permit the Corporation to bring Won to court after the latter's successful establishment of
his rights in civil case 26044 to the membership fee certificate 201, is to increase instead of to
diminish the number of suits, which is one of the purposes of an action of interpleader, with the
possibility that the latter would lose the benefits of the favorable judgment. This cannot be done
because having elected to take its chances of success in said civil case 26044, with full
knowledge of all the fact, the Corporation must submit to the consequences of defeat.

Besides, a successful litigant cannot later be impleaded by his defeated adversary in an

interpleader suit and compelled to prove his claim anew against other adverse claimants, as that
would in effect be a collateral attack upon the judgment.

In fine, the instant interpleader suit cannot prosper because the Corporation had already been
made independently liable in civil case 26044 and, therefore, its present application for
interpleader would in effect be a collateral attack upon the final judgment in the said civil case;
the appellee Lee had already established his rights to membership fee certificate 201 in the
aforesaid civil case and, therefore, this interpleader suit would compel him to establish his rights
anew, and thereby increase instead of diminish litigations, which is one of the purposes of an
interpleader suit, with the possibility that the benefits of the final judgment in the said civil case
might eventually be taken away from him; and because the Corporation allowed itself to be sued
to final judgment in the said case, its action of interpleader was filed inexcusably late, for which
reason it is barred by laches or unreasonable delay. (Wack-Wack Golf and Country Club vs. Won,
G.R. No. L-23851, March 26, 1976)
RCBC vs Metro Container Corporation

Facts: For failure of Ley Construction Corporation (LEYCON) to settle its loan obligations,
Rizal Commercial Banking Corporation (RCBC) instituted an extrajudicial foreclosure
proceeding against it. In a bidding, RCBC was adjudged the highest bidder. LEYCON promptly
filed an action for Nullification of Extrajudicial Foreclosure Sale and Damages against RCBC.
Meanwhile, RCBC consolidated its ownership over the property due to LEYCON's failure to
redeem the mortgaged property within the 12-month redemption period. By virtue thereof,
RCBC demanded rental payments from Metro Container Corporation (METROCAN) which was
leasing the mortgaged property from LEYCON.

On the other hand, LEYCON filed an action for Unlawful Detainer against METROCAN before
the MeTC. Consequently, METROCAN filed a complaint for Interpleader against LEYCON and
RCBC before the RTC to compel them to interplead and litigate their several claims among
themselves and to determine which among them shall rightfully receive the payment of monthly
rentals on the subject property.

On 31 October 1995, judgment was rendered in the Unlawful Detainer case, which, among other
things, ordered METROCAN to pay LEYCON whatever rentals due on the subject premises.
The said decision became final and executory. By reason thereof, METROCAN and LEYCON
separately filed a motion to dismiss the interpleader case. However, the said motions were
dismissed for lack of merit. METROCAN appealed to the Court of Appeals which granted the
petition and ordered the dismissal of the interpleader case. Hence, RCBC filed the instant
petition.

Issue: May METROCAN unilaterally cause the dismissal of the interpleader case?
Held: Yes. An action of interpleader is afforded to protect a person not against double
liability but against double vexation in respect of one liability. It requires, as an indispensable
requisite, that conflicting claims upon the same subject matter are or may be made against the
plaintiff-in-interpleader who claims no interest whatever in the subject matter or an interest
which in whole or in part is not disputed by the claimants.

When the decision in the Unlawful Detainer case became final and executory, METROCAN has
no other alternative left but to pay the rentals to LEYCON. Precisely because there was already a
judicial fiat to METROCAN, there was no more reason to continue with the interpleader case.
Thus, METROCAN moved for the dismissal of the interpleader action not because it is no longer
interested but because there is no more need for it to pursue such cause of action. The decision in
the Unlawful Detainer case resolved the conflicting claims insofar as payment of rentals was
concerned.

RCBC was correct in saying that it is not bound by the decision in the Unlawful Detainer case. It
is not a party thereto. However, it could not compel METROCAN to pursue the interpleader
case. RCBC has other avenues to prove its claim. It is not bereft of other legal remedies. In fact,
the issue of ownership can very well be threshed out in the case for Nullification of Extrajudicial
Foreclosure Sale and Damages filed by LEYCON against RCBC. (RCBC vs Metro Container
Corporation, G.R. No. 127913. September 13, 2001)

BANK OF COMMERCE v. PLANTERS DEVELOPMENT BANK, GR Nos. 154470-71, 2012-

09-24

Facts:

Issues:

Ruling:

Principles:

In the exercise of its plenary legislative power, Congress may create administrative agencies
endowed with quasi-legislative and quasi-judicial powers. Necessarily, Congress likewise
defines the limits of an agency's jurisdiction in the same manner as it defines the jurisdiction... of
courts.[121] As... a result, it may happen that either a court or an administrative agency has
exclusive jurisdiction over a specific matter or both have concurrent jurisdiction on the same. It
may happen, too, that courts and agencies may willingly relinquish adjudicatory power that is
rightfully... theirs in favor of the other. One of the instances when a court may properly defer to
the adjudicatory authority of an agency is the applicability of the doctrine of primary jurisdiction.
Ocampo vs. Tirona Case Digest

Facts: Ocampo bought a parcel of land from Rosauro Breton. Ocampo then possessed and
administer the subject land although the TCT is not yet in his name. Ocampo notified Tirona,
who was a lessee occupying a portion of the subject land, about the sale. Tirona religiously paid
her rents to Ocampo. However, when the subject premises were declared under area for priority
development, Tirona invoked her right to first refusal and refused to pay her rent until the NHA
processed her papers. Ocampo filed a complaint for unlawful detainer. In her Answer, Tironas
asserted that Dona Yaneza was the owner of the land and not Ocampo. She likewise reiterated
that she has the right of first refusal over the land as it was included in the area of priority
development under PD 1517. The MTC ruled in favor of Ocampo.

In the RTC, Tirona changed her theory and disclosed that Alipio Breton is the registered owner
of the subject land. When Alipio Breton died, his children, Rosauro Breton and Maria Lourdes
Breton-Mendiola, inherited the subject land. Tirona claims she has never stopped paying her rent
to Maria Lourdes. Tirona also stated that Rosauro could not transfer ownership to the subject
land to Ocampo because Rosauro executed a deed of conveyance and waiver in favor of Maria
Lourdes. The RTC affirmed the decision of the MTC.

The CA considered partition of the estate of Alipio Breton as a prerequisite to Ocampos action;
hence, it dismissed the case.

Issues:
1. Has Ocampo the right to eject Tirona from the subject land?
2. Is the issue of ownership essential in a suit to eject a person illegally occupying a land?
3. Is the CA correct in holding that unlawful detainer had to wait for the results of the partition
proceedings?
4. What should have been filed by Tirona when she does not know the person to whom to pay the
rentals due?

Held:
1. Yes. Unlawful detainer cases are summary in nature. The elements to be proved and resolved
in unlawful detainer cases are the fact of lease and expiration or violation of its terms. All the
elements required for an unlawful detainer case to prosper are present. Ocampo notified Tirona
that he purchased the subject land from Tironas lessor. Tironas continued occupation of the
subject land amounted to acquiescence to Ocampos terms. However, Tirona eventually refused
to pay rent to Ocampo, thus violating the lease.
2. No. The issue of ownership is not essential to an action for unlawful detainer. The fact of the
lease and the expiration of its term are the only elements of the action. The defense of ownership
does not change the summary nature of the action. The affected party should raise the issue of
ownership in an appropriate action, because a certificate of title cannot be the subject of a
collateral attack.

In actions for forcible entry and unlawful detainer, the main issue is possession de facto,
independently of any claim of ownership or possession de jure that either party may set forth in
his pleadings, and an appeal does not operate to change the nature of the original action.

3. Unlawful detainer being a summary proceeding, it was error for the appellate court to include
the issue of ownership. Had the appellate court limited its ruling to the elements to be proved in a
case of unlawful detainer, Ocampo need not even prove his ownership. When the appellate court
ruled that the case of unlawful detainer had to wait for the results of the partition proceedings, it
effectively put ownership as the main issue in the case. The issue of ownership opens a virtual
Pandoras Box for Tirona and her supposed intervenor, Maria Lourdes Breton-Mendiola.

4. The good faith of Tirona is put in question in her preference for Maria Lourdes Breton-
Mendiola. As a stakeholder, Tirona should have used reasonable diligence in hailing the
contending claimants to court. Tirona need not have awaited actual institution of a suit by
Ocampo against her before filing a bill of interpleader. An action for interpleader is proper when
the lessee does not know the person to whom to pay rentals due to conflicting claims on the
property.

The action of interpleader is a remedy whereby a person who has property whether personal or
real, in his possession, or an obligation to render wholly or partially, without claiming any right
in both, or claims an interest which in whole or in part is not disputed by the conflicting
claimants, comes to court and asks that the persons who claim the said property or who consider
themselves entitled to demand compliance with the obligation, be required to litigate among
themselves, in order to determine finally who is entitled to one or the other thing. The remedy is
afforded not to protect a person against a double liability but to protect him against a double
vexation in respect of one liability. When the court orders that the claimants litigate among
themselves, there arises in reality a new action and the former are styled interpleaders, and in
such a case the pleading which initiates the action is called a complaint of interpleader and not a
cross-complaint. (Ocampo vs Tirona, G.R. No.147812. April 6, 2005)
Maglente vs. Padilla Case Digest

Facts: Philippine Realty Corp (PRC) owned a parcel of land in Intramuros, which it leased to
petitioners Maglente. The lease agreement included a right of first refusal in favor of Maglente,
as well as an agreement whereby PRC prohibited Maglente from subleasing the property.
Nonetheless, Maglente subleased the property to the private respondents. Later on, PRC decided
to sell the property and offered the land to Maglente in accordance with her right of first refusal.
Maglente intimated that she would exercise her right of first refusal to purchase the property.
However, PRC received a letter from the private respondents expressing their desire to purchase
the same property.

PRC filed a complaint for interpleader with the Manila RTC to determine who between the 2
parties had the right to purchase the property. The RTC ruled in favor of the Maglente, ordering
PRC to execute a deed of sale. PRC executed a deed of sale in favor of the petitioners, who then
filed a motion for a writ of possession. Private respondents objected on the ground that the trial
court's decision on the interpleader case merely resolved petitioners right to purchase the leased
property but did not declare them as the owners entitled to possession. RTC ruled in favor of the
respondents and denied the writ of possession. So the petitioners filed this special civil action for
certiorari.

Issue: Are petitioners entitled to a writ of possession after being adjudged (in the interpleader
case) as the proper parties to buy the subject property, considering that a deed of sale has already
been executed in their favor?

Held: No. A writ of possession shall issue only in the following instances: (1) land
registration proceedings; (2) extrajudicial foreclosure of mortgage of real property; (3) judicial
foreclosure of property provided that the mortgagor has possession and no third party has
intervened, and (4) execution sales. Here, petitioners seek the writ as a consequence of the trial
courts decision ordering the execution of a contract of sale/contract to sell in their favor. The writ
does not lie in such a case.

Furthermore, the trial courts decision in the interpleader case (affirmed by both the CA and the
SC) merely resolved the question of who, between petitioners and respondents, had the right to
purchase PRCs property. The directive was only for PRC to execute the necessary contract in
favor of petitioners as the winning parties, nothing else.

It was clear that, at that point, petitioners were not yet the owners of the property. The execution
of the deed of sale in their favor was only preliminary to their eventual acquisition of the
property. Likewise, although we stated in G.R. No. 111743 that the contract of sale between
petitioners and PRC had already been perfected, we refrained from declaring them the owners
since, pending the execution of the deed of sale or delivery of the property, ownership had yet to
transfer to them at that time.

Thus, petitioners argument that the trial courts writ of execution in the interpleader case carried
with it the corollary right to a writ of possession is without merit. A writ of possession
complements the writ of execution only when the right of possession or ownership has been
validly determined in a case directly relating to either.The interpleader case obviously did not
delve into that issue.

Furthermore, the rule is that the enforcement of a judgment may not vary or alter the tenor of the
judgment but must strictly conform to it. It should be in harmony with the judgment that gives it
life and not exceed it. We thus cannot fault the trial court for refusing to issue a writ of
possession to petitioners as its issuance would not be in conformity with the trial courts judgment
in the interpleader case.

Finally, petitioners cannot recover possession of the property via a mere motion. They must file
the appropriate action in court against respondents to recover possession. While this remedy can
delay their recovery, this Court cannot permit an abbreviated method without subverting the rules
and processes established for the orderly administration of justice. (Maglente vs. Padilla, G.R.
No. 148182, March 7, 2007)
 Imbong vs Ochoa
Substantial: Right to Life; Health; Religion; Free Speech; Privacy; Due Process Clause; Equal
Protection Clause

Procedural: Actual Case; Facial Challenge; Locus Standi; Declaratory Relief; One Subject One
Title Rule

IMBONG VS OCHOA

G.R. No. 204819 April 8, 2014

JAMES M. IMBONG and LOVELY-ANN C. IMBONG, for themselves and in behalf of their
minor children, LUCIA CARLOS IMBONG and BERNADETTE CARLOS IMBONG and
MAGNIFICAT CHILD DEVELOPMENT CENTER, INC., Petitioners,
vs.
HON. PAQUITO N. OCHOA, JR., Executive Secretary, HON. FLORENCIO B. ABAD,
Secretary, Department of Budget and Management, HON. ENRIQUE T. ONA, Secretary,
Department of Health, HON. ARMIN A. LUISTRO, Secretary, Department of Education,
Culture and Sports and HON. MANUELA. ROXAS II, Secretary, Department of Interior and
Local Government, Respondents.

Facts:

Republic Act (R.A.) No. 10354, otherwise known as the Responsible Parenthood and
Reproductive Health Act of 2012 (RH Law), was enacted by Congress on December 21, 2012.

Challengers from various sectors of society are questioning the constitutionality of the said Act.
The petitioners are assailing the constitutionality of RH Law on the following grounds:

SUBSTANTIAL ISSUES:

1. The RH Law violates the right to life of the unborn.

2. The RH Law violates the right to health and the right to protection against hazardous products.

3. The RH Law violates the right to religious freedom.

 4. The RH Law violates the constitutional provision on involuntary servitude.

5. The RH Law violates the right to equal protection of the law.

6. The RH Law violates the right to free speech.

7. The RH Law is void-for-vagueness in violation of the due process clause of the Constitution.

8. The RH Law intrudes into the zone of privacy of ones family protected by the Constitution

PROCEDURAL: Whether the Court may exercise its power of judicial review over the
controversy.

1. Power of Judicial Review

2. Actual Case or Controversy

3. Facial Challenge

4. Locus Standi

5. Declaratory Relief

6. One Subject/One Title Rule

Issue/s:

SUBSTANTIAL ISSUES:

Whether or not (WON) RA 10354/Reproductive Health (RH) Law is unconstitutional for

violating the:

1. Right to life

2. Right to health

3. Freedom of religion and right to free speech

4. Right to privacy (marital privacy and autonomy)

5. Freedom of expression and academic freedom

 6. Due process clause

7. Equal protection clause

8. Prohibition against involuntary servitude

PROCEDURAL:

Whether the Court can exercise its power of judicial review over the controversy.

1. Actual Case or Controversy

2. Facial Challenge

3. Locus Standi

4. Declaratory Relief

5. One Subject/One Title Rule

Discussions:

PROCEDURAL

Judicial Review Jurisprudence is replete with the rule that the power of judicial review is
limited by four exacting requisites: (a) there must be an actual case or controversy; (b) the
petitioners must possess locus standi; (c) the question of constitutionality must be raised at the
earliest opportunity; and (d) the issue of constitutionality must be the lis mota of the case.

Actual Controversy: An actual case or controversy means an existing case or controversy that is
appropriate or ripe for determination, not conjectural or anticipatory, lest the decision of the court
would amount to an advisory opinion. It must concern a real, tangible and not merely a
theoretical question or issue. There ought to be an actual and substantial controversy admitting of
specific relief through a decree conclusive in nature, as distinguished from an opinion advising
what the law would be upon a hypothetical state of facts. Corollary to the requirement of an
actual case or controversy is the requirement of ripeness. A question is ripe for adjudication when
the act being challenged has had a direct adverse effect on the individual challenging it. For a
case to be considered ripe for adjudication, it is a prerequisite that something has then been
accomplished or performed by either branch before a court may come into the picture, and the
petitioner must allege the existence of an immediate or threatened injury to himself as a result of
the challenged action. He must show that he has sustained or is immediately in danger of
sustaining some direct injury as a result of the act complained of
Facial Challenge: A facial challenge, also known as a First Amendment Challenge, is one that is
launched to assail the validity of statutes concerning not only protected speech, but also all other
rights in the First Amendment. These include religious freedom, freedom of the press, and the
right of the people to peaceably assemble, and to petition the Government for a redress of
grievances. After all, the fundamental right to religious freedom, freedom of the press and
peaceful assembly are but component rights of the right to ones freedom of expression, as they
are modes which ones thoughts are externalized.

Locus Standi: Locus standi or legal standing is defined as a personal and substantial interest in a
case such that the party has sustained or will sustain direct injury as a result of the challenged
governmental act. It requires a personal stake in the outcome of the controversy as to assure the
concrete adverseness which sharpens the presentation of issues upon which the court so largely
depends for illumination of difficult constitutional questions.

Transcendental Importance: the Court leans on the doctrine that the rule on standing is a
matter of procedure, hence, can be relaxed for non-traditional plaintiffs like ordinary citizens,
taxpayers, and legislators when the public interest so requires, such as when the matter is of
transcendental importance, of overreaching significance to society, or of paramount public
interest.

One Subject-One Title: The one title-one subject rule does not require the Congress to
employ in the title of the enactment language of such precision as to mirror, fully index or
catalogue all the contents and the minute details therein. The rule is sufficiently complied with if
the title is comprehensive enough as to include the general object which the statute seeks to
effect, and where, as here, the persons interested are informed of the nature, scope and
consequences of the proposed law and its operation. Moreover, this Court has invariably adopted
a liberal rather than technical construction of the rule so as not to cripple or impede legislation.
The one subject/one title rule expresses the principle that the title of a law must not be so
uncertain that the average person reading it would not be informed of the purpose of the
enactment or put on inquiry as to its contents, or which is misleading, either in referring to or
indicating one subject where another or different one is really embraced in the act, or in omitting
any expression or indication of the real subject or scope of the act.

Declaration of Unconstitutionality: Orthodox view: An unconstitutional act is not a law; it

confers no rights; it imposes no duties; it affords no protection; it creates no office; it is, in legal
contemplation, as inoperative as though it had never been passed. Modern view: Under this view,
the court in passing upon the question of constitutionality does not annul or repeal the statute if it
finds it in conflict with the Constitution. It simply refuses to recognize it and determines the
rights of the parties just as if such statute had no existence. But certain legal effects of the statute
prior to its declaration of unconstitutionality may be recognized. Requisites for partial
unconstitutionality: (1) The Legislature must be willing to retain the valid portion(s), usually
shown by the presence of a separability clause in the law; and (2) The valid portion can stand
independently as law.
Ruling/s:

SUBSTANTIAL

1. Majority of the Members of the Court believe that the question of when life begins is a scientific
and medical issue that should not be decided, at this stage, without proper hearing and
evidence. However, they agreed that individual Members could express their own views on this
matter.

Article II, Section 12 of the Constitution states: The State recognizes the sanctity of family life
and shall protect and strengthen the family as a basic autonomous social institution. It shall
equally protect the life of the mother and the life of the unborn from conception.

In its plain and ordinary meaning (a canon in statutory construction), the traditional meaning of
conception according to reputable dictionaries cited by the ponente is that life begins at
fertilization. Medical sources also support the view that conception begins at fertilization.

The framers of the Constitution also intended for (a) conception to refer to the moment of
fertilization and (b) the protection of the unborn child upon fertilization. In addition, they did
not intend to ban all contraceptives for being unconstitutional; only those that kill or destroy the
fertilized ovum would be prohibited. Contraceptives that actually prevent the union of the male
sperm and female ovum, and those that similarly take action before fertilization should be
deemed non-abortive, and thus constitutionally permissible.

The intent of the framers of the Constitution for protecting the life of the unborn child was to
prevent the Legislature from passing a measure prevent abortion. The Court cannot interpret this
otherwise. The RH Law is in line with this intent and actually prohibits abortion. By using the
word or in defining abortifacient (Section 4(a)), the RH Law prohibits not only drugs or
devices that prevent implantation but also those that induce abortion and induce the destruction
of a fetus inside the mothers womb. The RH Law recognizes that the fertilized ovum already has
life and that the State has a bounded duty to protect it.

However, the authors of the IRR gravely abused their office when they redefined the meaning of
abortifacient by using the term primarily. Recognizing as abortifacients only those that
primarily induce abortion or the destruction of a fetus inside the mothers womb or the
prevention of the fertilized ovum to reach and be implanted in the mothers womb (Sec. 3.01(a)
of the IRR) would pave the way for the approval of contraceptives that may harm or destroy the
life of the unborn from conception/fertilization. This violates Section 12, Article II of the
Constitution. For the same reason, the definition of contraceptives under the IRR (Sec 3.01(j)),
which also uses the term primarily, must be struck down.

2. The RH Law does not intend to do away with RA 4729 (1966). With RA 4729 in place, the Court
believes adequate safeguards exist to ensure that only safe contraceptives are made available to
the public. In fulfilling its mandate under Sec. 10 of the RH Law, the DOH must keep in mind the
provisions of RA 4729: the contraceptives it will procure shall be from a duly licensed drug store
or pharmaceutical company and that the actual distribution of these contraceptive drugs and
devices will be done following a prescription of a qualified medical practitioner.
Meanwhile, the requirement of Section 9 of the RH Law is to be considered mandatory only
after these devices and materials have been tested, evaluated and approved by the FDA.
Congress cannot determine that contraceptives are safe, legal, non-abortificient and effective.

3. The Court cannot determine whether or not the use of contraceptives or participation in support
of modern RH measures (a) is moral from a religious standpoint; or, (b) right or wrong according
to ones dogma or belief. However, the Court has the authority to determine whether or not the
RH Law contravenes the Constitutional guarantee of religious freedom.

The State may pursue its legitimate secular objectives without being dictated upon the policies of
any one religion. To allow religious sects to dictate policy or restrict other groups would violate
Article III, Section 5 of the Constitution or the Establishment Clause. This would cause the State
to adhere to a particular religion, and thus, establishes a state religion. Thus, the State
can enhance its population control program through the RH Law even if the promotion of
contraceptive use is contrary to the religious beliefs of e.g. the petitioners.

4. Section 23A (2)(i) of the RH Law, which permits RH procedures even with only the consent of the
spouse undergoing the provision (disregarding spousal content), intrudes into martial privacy
and autonomy and goes against the constitutional safeguards for the family as the basic social
institution. Particularly, Section 3, Article XV of the Constitution mandates the State to defend:
(a) the right of spouses to found a family in accordance with their religious convictions and the
demands of responsible parenthood and (b) the right of families or family associations to
participate in the planning and implementation of policies and programs that affect them. The
RH Law cannot infringe upon this mutual decision-making, and endanger the institutions of
marriage and the family.

The exclusion of parental consent in cases where a minor undergoing a procedure is already a
parent or has had a miscarriage (Section 7 of the RH Law) is also anti-family and violates Article
II, Section 12 of the Constitution, which states: The natural and primary right and duty of
parents in the rearing of the youth for civic efficiency and the development of moral character
shall receive the support of the Government. In addition, the portion of Section 23(a)(ii) which
reads in the case of minors, the written consent of parents or legal guardian or, in their absence,
persons exercising parental authority or next-of-kin shall be required only in elective surgical
procedures is invalid as it denies the right of parental authority in cases where what is involved
is non-surgical procedures.

However, a minor may receive information (as opposed to procedures) about family planning
services. Parents are not deprived of parental guidance and control over their minor child in this
situation and may assist her in deciding whether to accept or reject the information received. In
addition, an exception may be made in life-threatening procedures.

5. The Court declined to rule on the constitutionality of Section 14 of the RH Law, which mandates
the State to provide Age-and Development-Appropriate Reproductive Health Education.
Although educators might raise their objection to their participation in the RH education
program, the Court reserves its judgment should an actual case be filed before it.
Any attack on its constitutionality is premature because the Department of Education has not yet
formulated a curriculum on age-appropriate reproductive health education.

Section 12, Article II of the Constitution places more importance on the role of parents in the
development of their children with the use of the term primary. The right of parents in
upbringing their youth is superior to that of the State.

The provisions of Section 14 of the RH Law and corresponding provisions of the IRR
supplement (rather than supplant) the right and duties of the parents in the moral development of
their children.

By incorporating parent-teacher-community associations, school officials, and other interest

groups in developing the mandatory RH program, it could very well be said that the program will
be in line with the religious beliefs of the petitioners.

6. The RH Law does not violate the due process clause of the Constitution as the definitions of
several terms as observed by the petitioners are not vague.

The definition of private health care service provider must be seen in relation to Section 4(n)
of the RH Law which defines a public health service provider. The private health care
institution cited under Section 7 should be seen as synonymous to private health care service
provider.

The terms service and methods are also broad enough to include providing of information
and rendering of medical procedures. Thus, hospitals operated by religious groups are exempted
from rendering RH service and modern family planning methods (as provided for by Section 7 of
the RH Law) as well as from giving RH information and procedures.

The RH Law also defines incorrect information. Used together in relation to Section 23 (a)(1),
the terms incorrect and knowingly connote a sense of malice and ill motive to mislead or
misrepresent the public as to the nature and effect of programs and services on reproductive
health.

7. To provide that the poor are to be given priority in the governments RH program is not a
violation of the equal protection clause. In fact, it is pursuant to Section 11, Article XIII of the
Constitution, which states that the State shall prioritize the needs of the underprivileged, sick
elderly, disabled, women, and children and that it shall endeavor to provide medical care to
paupers.

The RH Law does not only seek to target the poor to reduce their number, since Section 7 of the
RH Law prioritizes poor and marginalized couples who are suffering from fertility issues and
desire to have children. In addition, the RH Law does not prescribe the number of children a
couple may have and does not impose conditions upon couples who intend to have children. The
RH Law only seeks to provide priority to the poor.
The exclusion of private educational institutions from the mandatory RH education program
under Section 14 is valid. There is a need to recognize the academic freedom of private
educational institutions especially with respect to religious instruction and to consider their
sensitivity towards the teaching of reproductive health education

8. The requirement under Sec. 17 of the RH Law for private and non-government health care
service providers to render 48 hours of pro bonoRH services does not amount to involuntary
servitude, for two reasons. First, the practice of medicine is undeniably imbued with public
interest that it is both the power and a duty of the State to control and regulate it in order to
protect and promote the public welfare. Second, Section 17 only encourages private and non-
government RH service providers to render pro bono Besides the PhilHealth accreditation, no
penalty is imposed should they do otherwise.

However, conscientious objectors are exempt from Sec. 17 as long as their religious beliefs do
not allow them to render RH service, pro bono or otherwise

PROCEDURAL

1. In this case, the Court is of the view that an actual case or controversy exists and that the same is
ripe for judicial determination. Considering that the RH Law and its implementing rules have
already taken effect and that budgetary measures to carry out the law have already been passed,
it is evident that the subject petitions present a justiciable controversy. As stated earlier, when
an action of the legislative branch is seriously alleged to have infringed the Constitution, it not
only becomes a right, but also a duty of the Judiciary to settle the dispute.

Moreover, the petitioners have shown that the case is so because medical practitioners or medical
providers are in danger of being criminally prosecuted under the RH Law for vague violations
thereof, particularly public health officers who are threatened to be dismissed from the service
with forfeiture of retirement and other benefits. They must, at least, be heard on the matter now.

2. In this jurisdiction, the application of doctrines originating from the U.S. has been generally
maintained, albeit with some modifications. While the Court has withheld the application of
facial challenges to strictly penal statues, it has expanded its scope to cover statutes not only
regulating free speech, but also those involving religious freedom, and other fundamental rights.
The underlying reason for this modification is simple. For unlike its counterpart in the U.S., this
Court, under its expanded jurisdiction, is mandated by the Fundamental Law not only to settle
actual controversies involving rights which are legally demandable and enforceable, but also to
determine whether or not there has been a grave abuse of discretion amounting to lack or
excess of jurisdiction on the part of any branch or instrumentality of the Government. Verily, the
framers of Our Constitution envisioned a proactive Judiciary, ever vigilant with its duty to
maintain the supremacy of the Constitution.
Consequently, considering that the foregoing petitions have seriously alleged that the
constitutional human rights to life, speech and religion and other fundamental rights mentioned
above have been violated by the assailed legislation, the Court has authority to take cognizance
of these kindred petitions and to determine if the RH Law can indeed pass constitutional scrutiny.
To dismiss these petitions on the simple expedient that there exist no actual case or controversy,
would diminish this Court as a reactive branch of government, acting only when the
Fundamental Law has been transgressed, to the detriment of the Filipino people.

3. Even if the constitutionality of the RH Law may not be assailed through an as-applied challenge,
still, the Court has time and again acted liberally on the locus standi requirement. It has
accorded certain individuals standing to sue, not otherwise directly injured or with material
interest affected by a Government act, provided a constitutional issue of transcendental
importance is invoked. The rule on locus standi is, after all, a procedural technicality which the
Court has, on more than one occasion, waived or relaxed, thus allowing non-traditional plaintiffs,
such as concerned citizens, taxpayers, voters or legislators, to sue in the public interest, albeit
they may not have been directly injured by the operation of a law or any other government act.

The present action cannot be properly treated as a petition for prohibition, the transcendental
importance of the issues involved in this case warrants that the Court set aside the technical
defects and take primary jurisdiction over the petition at bar. One cannot deny that the issues
raised herein have potentially pervasive influence on the social and moral well being of this
nation, specially the youth; hence, their proper and just determination is an imperative need. This
is in accordance with the well-entrenched principle that rules of procedure are not inflexible tools
designed to hinder or delay, but to facilitate and promote the administration of justice. Their strict
and rigid application, which would result in technicalities that tend to frustrate, rather than
promote substantial justice, must always be eschewed.

4. Most of the petitions are praying for injunctive reliefs and so the Court would just consider them
as petitions for prohibition under Rule 65, over which it has original jurisdiction. Where the case
has far-reaching implications and prays for injunctive reliefs, the Court may consider them as
petitions for prohibition under Rule 65.

5. The RH Law does not violate the one subject/one bill rule. In this case, a textual analysis of the
various provisions of the law shows that both reproductive health and responsible
parenthood are interrelated and germane to the overriding objective to control the population
growth. As expressed in the first paragraph of Section 2 of the RH Law:

SEC. 2. Declaration of Policy. The State recognizes and guarantees the human rights of all
persons including their right to equality and nondiscrimination of these rights, the right to
sustainable human development, the right to health which includes reproductive health, the right
to education and information, and the right to choose and make decisions for themselves in
accordance with their religious convictions, ethics, cultural beliefs, and the demands of
responsible parenthood.

Considering the close intimacy between reproductive health and responsible parenthood
which bears to the attainment of the goal of achieving sustainable human development as
stated under its terms, the Court finds no reason to believe that Congress intentionally sought to
deceive the public as to the contents of the assailed legislation.

Accordingly, the Court declares R.A. No. 10354 as NOT UNCONSTITUTIONAL except with
respect to the following provisions which are declared UNCONSTITUTIONAL:

1) Section 7 and the corresponding provision in the RH-IRR insofar as they: a) require private
health facilities and non-maternity specialty hospitals and hospitals owned and operated by a
religious group to refer patients, not in an emergency or life-threatening case, as defined under
Republic Act No. 8344, to another health facility which is conveniently accessible; and b) allow
minor-parents or minors who have suffered a miscarriage access to modem methods of family
planning without written consent from their parents or guardian/s;

2) Section 23(a)(l) and the corresponding provision in the RH-IRR, particularly Section 5 .24
thereof, insofar as they punish any healthcare service provider who fails and or refuses to
disseminate information regarding programs and services on reproductive health regardless of
his or her religious beliefs.

3) Section 23(a)(2)(i) and the corresponding provision in the RH-IRR insofar as they allow a
married individual, not in an emergency or life-threatening case, as defined under Republic Act
No. 8344, to undergo reproductive health procedures without the consent of the spouse;

4) Section 23(a)(2)(ii) and the corresponding provision in the RH-IRR insofar as they limit the
requirement of parental consent only to elective surgical procedures.

5) Section 23(a)(3) and the corresponding provision in the RH-IRR, particularly Section 5.24
thereof, insofar as they punish any healthcare service provider who fails and/or refuses to refer a
patient not in an emergency or life-threatening case, as defined under Republic Act No. 8344, to
another health care service provider within the same facility or one which is conveniently
accessible regardless of his or her religious beliefs;

6) Section 23(b) and the corresponding provision in the RH-IRR, particularly Section 5 .24
thereof, insofar as they punish any public officer who refuses to support reproductive health
programs or shall do any act that hinders the full implementation of a reproductive health
program, regardless of his or her religious beliefs;

7) Section 17 and the corresponding prov1s10n in the RH-IRR regarding the rendering of pro
bona reproductive health service in so far as they affect the conscientious objector in securing
PhilHealth accreditation; and

8) Section 3.0l(a) and Section 3.01 G) of the RH-IRR, which added the qualifier primarily in
defining abortifacients and contraceptives, as they are ultra vires and, therefore, null and void for
contravening Section 4(a) of the RH Law and violating Section 12, Article II of the Constitution.