One Subject-One Title
The petitioners also question the constitutionality of the RH Law, claiming that it violates
Section 26(1 ), Article VI of the Constitution,122 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.123
To belittle the challenge, the respondents insist that the RH Law is not a birth or population
control measure,124 and that the concepts of "responsible parenthood" and "reproductive
health" are both interrelated as they are inseparable.125
Despite efforts to push the RH Law as a reproductive health law, the Court sees it as
principally a population control measure. The corpus of the RH Law is geared towards the
reduction of the country's population. While it claims to save lives and keep our women and
children healthy, it also promotes pregnancy-preventing products. As stated earlier, the RH
Law emphasizes the need to provide Filipinos, especially the poor and the marginalized, with
access to information on the full range of modem family planning products and methods.
These family planning methods, natural or modem, however, are clearly geared towards the
prevention of pregnancy.
For said reason, the manifest underlying objective of the RH Law is to reduce the number of
births in the country.
It cannot be denied that the measure also seeks to provide pre-natal and post-natal care as
well. A large portion of the law, however, covers the dissemination of information and
provisions on access to medically-safe, non-abortifacient, effective, legal, affordable, and
quality reproductive health care services, methods, devices, and supplies, which are all
intended to prevent pregnancy.
The Court, thus, agrees with the petitioners' contention that the whole idea of contraception
pervades the entire RH Law. It is, in fact, the central idea of the RH Law.126 Indeed, remove
the provisions that refer to contraception or are related to it and the RH Law loses its very
foundation.127 As earlier explained, "the other positive provisions such as skilled birth
attendance, maternal care including pre-and post-natal services, prevention and
management of reproductive tract infections including HIV/AIDS are already provided for in
the Magna Carta for Women."128
Be that as it may, the RH Law does not violate the one subject/one bill rule. In Benjamin E.
Cawaling, Jr. v. The Commission on Elections and Rep. Francis Joseph G Escudero, it was
written:
It is well-settled that the "one title-one subject" rule does not require the Congress to employ
in the title of the enactment language of such precision as to mirror, fully index or catalogue
all the contents and the minute details therein. The rule is sufficiently complied with if the
title is comprehensive enough as to include the general object which the statute seeks to
effect, and where, as here, the persons interested are informed of the nature, scope and