Case Digest: Imbong vs. Ochoa; G.R. No. 204819 April 8, 2014

                Equal Protection of the Laws | Constitutional Law


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. This law guaranteed universal and free access to nearly all modern contraceptives to all citizens, including those living in poverty, through government health centers. The RH Law was immediately challenged by various religious and conservative groups.

Issue:

WoN the Section 5.24 of the IRR of RH Law violates the equal protection clause as regards to the alleged discriminatory nature against the poor.

Held:

NO. To provide that the poor are to be given priority in the government's reproductive health care program is not a violation of the equal protection clause. In fact, it is pursuant to Section 11, Article XIII of the Constitution which recognizes the distinct necessity to address the needs of the underprivileged by providing that they be given priority in addressing the health development of the people.

The RH Law prioritizes poor and marginalized couples who are suffering from fertility issues and desire to have children. There is, therefore, no merit to the contention that the RH Law only seeks to target the poor to reduce their number.


Ratio:

The equal protection clause is aimed at all official state actions, not just those of the legislature. Its inhibitions cover all the departments of the government including the political and executive departments, and extend to all actions of a state denying equal protection of the laws, through whatever agency or whatever guise is taken.

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