IMBONG v.

OCHOA

G.R. No. 204819 April 8, 2014

FACTS:

Shortly after the President placed his imprimatur on Republic Act (R.A.) No. 10354, otherwise
known as the Responsible Parenthood and Reproductive Health Act of 2012 (RH Law), challengers from
various sectors of society came knocking on the doors of the Court, beckoning it to wield the sword that
strikes down constitutional disobedience. Aware of the profound and lasting impact that its decision
may produce, the Court now faces the controversy, as presented in fourteen (14) petitions and two (2)
petitions-in-intervention.

The petitioners are one in praying that the entire RH Law be declared unconstitutional.

ISSUES:

RULING:

SUBSTANTIVE:

Whether the RH law is unconstitutional:

Involuntary Servitude

The notion of involuntary servitude connotes the presence of force, threats, intimidation or other
similar means of coercion and compulsion. A reading of the assailed provision, however, reveals that it
only encourages private and non- government reproductive healthcare service providers to render pro
bono service. Other than non-accreditation with PhilHealth, no penalty is imposed should they choose
to do otherwise. Private and non-government reproductive healthcare service providers also enjoy the
liberty to choose which kind of health service they wish to provide, when, where and how to provide it
or whether to provide it all. Clearly, therefore, no compulsion, force or threat is made upon them to
render pro bono service against their will. While the rendering of such service was made a prerequisite
to accreditation with PhilHealth, the Court does not consider the same to be an unreasonable burden,
but rather, a necessary incentive imposed by Congress in the furtherance of a perceived legitimate state
interest. Consistent with what the Court had earlier discussed, however, it should be emphasized that
conscientious objectors are exempt from this provision as long as their religious beliefs and convictions
do not allow them to render reproductive health service, pro bona or otherwise