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Imbong v. Ochoa, GR 204819, 8 April 2014, En Banc
Fourteen petitions and two petitions-in-intervention were filed against the Republic Act (R.A.) No. 10354, otherwise known as the Responsible Parenthood and Reproductive Health Act of 2012 (RH Law), which was enacted by Congress on December 21, 2012. Petitioners were assailing the constitutionality of RH Law on the grounds that it violates the right to life of the unborn, the right to health and the right to protection against hazardous products, and the right to religious freedom.
They averred that RH Law violates the constitutional guarantee respecting religion as it authorizes the use of public funds for the procurement of contraceptives. In addition, the use of public funds for purposes that are believed to be contrary to their beliefs is included in the constitutional mandate ensuring religious freedom.
Respondents contended that RH Law only seeks to serve the public interest by providing accessible, effective and quality reproductive health services to ensure maternal and child health, in line with the State's duty to bring to reality the social justice health guarantees of the Constitution, and that what the law only prohibits are those acts or practices, which deprive others of their right to reproductive health. They asserted that the assailed law only seeks to guarantee informed choice, which is an assurance that no one will be compelled to violate his religion against his free will. They added that by asserting that only natural family planning should be allowed, the petitioners are effectively going against the constitutional right to religious freedom, the same right they invoked to assail the constitutionality of the RH Law.
Whether or not the RH Law is unconstitutional for violating the right to religious freedom.
No. The Court held RH Law not unconstitutional except with respect to certain provisions. However, on the issue whether the same violates the right of religious freedom, the Court ruled that it does not have the authority to determine the same.
While the Supreme Court stands without authority to rule on ecclesiastical matters, as vanguard of the Constitution, it does have authority to determine whether the Reproductive Health (RH) Law contravenes the guarantee of religious freedom.
It is not within the province of the Court to determine whether the use of contraceptives or one’s participation in the support of modern reproductive health measures is moral from a religious standpoint or whether the same is right or wrong according to one’s dogma or belief. For the Court has declared that matters dealing with “faith, practice, doctrine, form of worship, ecclesiastical law, custom and rule of a church are unquestionably ecclesiastical matters which are outside the province of the civil courts.” The jurisdiction of the Court extends only to public and secular morality. Whatever pronouncement the Court makes in the case at bench should be understood only in this realm where it has authority. Stated otherwise, while the Court stands without authority to rule on ecclesiastical matters, as vanguard of the Constitution, it does have authority to determine whether the RH Law contravenes the guarantee of religious freedom.
In a situation where the free exercise of religion is allegedly burdened by government legislation or practice, the compelling state interest test in line with the Court’s espousal of the Doctrine of Benevolent Neutrality (Estrada v. Escritor), finds application. In this case, the conscientious objector’s claim to religious freedom would warrant an exemption from obligations under the RH Law, unless the government succeeds in demonstrating a more compelling state interest in the accomplishment of an important secular objective. Necessarily so, the plea of conscientious objectors for exemption from the Reproductive Health Law deserves no less than strict scrutiny.
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