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Due process: A statute or act suffers from the defect of vagueness when it lacks
comprehensible standards that men of common intelligence must necessarily guess its
meaning and differ as to its application.
Freedom of Religion: The Court will not rule on ecclesiastical matters. Conscientious
objectors are, as held by the Court, exempted as long as the Reproductive Health Bill goes
against their religious beliefs.
FACTS
This case involves consolidated petitions for certiorari and prohibition against the implementation
of the Reproductive Health Law.
The Reproductive Health Law was passed.
A TRO was issued against its implementation.
The Court issued a Status Quo Ante order.
Petitioners assail the constitutionality of the RH law for being vague as to private healthcare
service institution, and that it fails to define incorrect information.
Petitioners also assail that it violates equal protection because of its mandatory application to
only to public schools, and that it discriminates against the poor by making them the primary
target of the government programs.
A vague statute violates both procedural and substantive due process because it
1. Fails to inform its subjects of the conduct to do or to refrain from; and
2. Gives the enforcing authority unbridled discretion in determining what or
whom are punishable under the statute.
Institution and service provider are used synonymously in the law.
As to the private healthcare service provider, the Court agreed with the Office of the
Solicitor General (OSG) that its definition should be taken from the definition of
public healthcare service providers under section 4 of the law.
Plain meaning rule used for incorrect information.
From its plain meaning, the word "incorrect" here denotes failing to agree
with a copy or model or with established rules; inaccurate, faulty; failing to
agree with the requirements of duty, morality or propriety; and failing to
coincide with the truth.
The word "knowingly" means with awareness or deliberateness that is
intentional.
The Court will not rule on ecclesiastical matters. Conscientious objectors are, as held
by the Court, exempted as long as the Reproductive Health Bill goes against their
religious beliefs. Hence, the following provisions are unconstitutional as they infringe
upon the freedom of religion of conscientious objectors.
Section 23(a)(1) which punishes any healthcare service provider who refuses
to disseminate information regarding programs and services on reproductive
health regardless of his or her religious beliefs.
Section 23(a)(3) which punishes healthcare service providers who fail or
refuse to refer a patient to another healthcare service provider within the same
facility regardless of his or her religious beliefs.
Section 23(b) which punishes any public officer who refuses to support
reproductive health programs regardless of his or her beliefs.
Section 17 regarding pro bono services insofar as they affect the
conscientious objector in securing PhilHealth accreditation.