6 However, as mentioned earlier, the state party has continued to prioritize religious ideologies over women’s health and well-being as the court’s decision in Imbong allowed both individuals and institutions to be “conscientious objectors.”57 Under the implementing rules of the RPRHA, a hospital owned and operated by a religious group, or classified as a non-maternity specialty hospital, may be exempt from providing the full range of modern family planning methods and an individual may refuse to deliver reproductive health care information or services as a “conscientious objector.”58 Since 2016, the state party has not prevented any of these institutions from refusing to provide modern contraceptives and has even facilitated their exercise of such refusal by issuing the “Guidelines on the Registration and Mapping of Conscientious Objectors and Exempt Health Facilities” (DoH Guidelines).59 The PCHR has called for the review and amendment of the RPRHA particularly to address the provisions on the scope of refusals of care based on religion and accountability of public officials who refuse to implement the RPRHA.60 Further, under the RPRHA as amended by Imbong, there is no longer any duty to refer “nonemergency” cases, including those involving access to modern contraceptives, to an alternative and accessible health care provider.61 The Court explained that creating a duty to refer will violate the “religious belief and conviction of a conscientious objector” and is a “false compromise because it makes pro-life health providers complicit in the performance of an act that they find morally repugnant or offensive.”62 The DoH Guidelines outlined the requirements for an individual health care provider to refuse to provide care based on “religious or ethical convictions” without any duty to refer except in emergency or serious cases.63 Similar requirements and the lack of duty to refer apply to “exempt health facilities” which are private non-maternity specialty hospitals or health facilities owned and operated by a religious group and are exempt from providing the full range of modern contraceptives. 64 Proposed recommendations: Amend the RPRHA to clarify that public health officials who are not health care providers cannot legally refuse to implement the RPRHA based on religious grounds and ensure effective accountability mechanisms are in place and functioning to end impunity for acts committed by any public official that hinders or interferes with women’s and girls’ access to reproductive health information and services. Strengthen the mandate of PCHR and ensure that its resolutions and findings of violations particularly on women’s and girl’s reproductive rights are legally binding and enforceable. Since 2016, the state party has failed to hold local government officials accountable for refusing to implement the RPRHA. To date, no public official has been held liable for the grave impact of the Manila executive orders—which were the subjects of the Committee’s special inquiry—on the health and rights of women in Manila. In Imbong, the Court declared unconstitutional the provision which penalizes any public officer who, regardless of his or her religious beliefs, refuses to support reproductive health programs or participates in any act that hinders the full implementation of a reproductive health program.65 Since 2016, the negative impact on accountability of the Imbong decision was recognized by the PCHR when it took note of Sorsogon City’s Executive Order 3 (EO 3)—which declared the city as “pro-life” and resulted in the withdrawal of modern contraceptives in local health facilities66— and recommended that the state party review the RPRHA particularly on the “absence of