Case Digest: Imbong v. Ochoa 721 SCRA 146

ISSUE:  Whether or not RH Law violated the one subject-one title rule under the Constitution 

FACTS:  Petitioners question the constitutionality of the RH Law, claiming that it violates Section 26(1), Article VI of the Constitution, prescribing the one subject-one title rule. According to them, being one for reproductive health with responsible parenthood, the assailed legislation violates the constitutional standards of due process by concealing its true intent – to act as a population control measure. On the other hand, respondents insist that the RH Law is not a birth or population control measure, and that the concepts of “responsible parenthood” and “reproductive health” are both interrelated as they are inseparable. 

DECISION:  Partly Granted 

RATIO DECIDENDI:  No. 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. 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.