available at http://www.guttmacher.org/pubs/2006/08/08/PhilippinesUPIA.pdf. See also id., at 21 ("Complications
following an unsafe abortion can include retained pregnancy tissue, infection, hemorrhage, septic shock, anemia,
abdominal injury (including uterine perforation), cervical or bowel damage, and toxic reactions to chemicals or
drugs used to induce the abortion. Over the long term, such complications may lead to chronic problems such as
pelvic infection, which increases the risk of ectopic pregnancy and infertility. In the most extreme cases, women
can die from complications"); CENTER FOR REPRODUCTIVE RIGHTS, FORSAKEN LIVES, supra note 20, at 14.
122
Singh, CAUSES AND CONSEQUENCES, supra note 121, at 22.
123
Sheila Crisostomo, RH to help stop rise in abortion cases – DOH, THE PHILIPPINE STAR (Mar. 7, 2014),
http://www.philstar.com/headlines/2014/03/07/1298062/rh-help-stop-rise-abortion-cases-doh.
124
CEDAW Committee, Concluding Observations: Philippines, supra note 5, para. 28.
125
CENTER FOR REPRODUCTIVE RIGHTS, FORSAKEN LIVES, supra note 20, at 55 (citing Metro Manila-based NGO,
Interview with Gina, Metro Manila (Jan. 29, 2009) ("I was left alone lying there, wondering when they would
attend to me…. My back was totally soaked in blood. Yet, nobody came to my aid.")); Center for Reproductive
Rights, Documentation Report, Focus Group Discussion on Post-Abortion Care, Profile of Angel (May 27, 2014)
[hereinafter FGD Report] (copy on file with the Center) ("the hospital staff, humiliated her in front of other
patients in the Emergency Room, shouting at the top of her voice, calling her mamamatay-baby (baby
murderer) … she was made to wait in the Operating Room which lasted for 24 hours"); FGD Report, Profile of
Beth ("Beth had a traumatic experience because she was not taken care of by the nurses and she almost died.")
126
CENTER FOR REPRODUCTIVE RIGHTS, FORSAKEN LIVES, supra note 20, at 56 (citing Christy Marfil, counsellor
at the Institute for Social Studies and Action, Interview with Jess, Quezon City (Mar. 20, 2009) ("Many women
who go to public hospitals are actually ridiculed and not treated as soon as they come in bleeding. The hospital
staff believe that they are supposed to give the women a “lesson” by threatening her [with police or media
exposure] or making her wait for her turn or not providing immediate action even if the woman is all blood[y] and
shaking from infections.")); FGD Report, supra note 125, Profile of Alice ("When she reached the hospital, she
was not given immediate medical attention because the hospital staff wanted her to admit first that she had an
abortion."); Profile of Nely ("She pleaded that she be given medical attention but the doctors ignored her pleas.
Every time she pleaded, they would ask her to admit what really happened and continued to ignore her when they
failed to get her to admit that she had an abortion.")
127
FGD Report, supra note 125, Profile of Kathleen ("She stayed at the hospital for almost two hours but she was
not admitted. The hospital staff told her "baka madamay ang hospital" (the hospital may face liability)."); Profile
of Medy ("She was asked to divulge what drug she took and to admit that she had an abortion, otherwise, they
threatened not to admit her at the hospital and to file criminal charges against her."); Profile of Diane (who was
refused medical treatment to remove the remaining products of conception at three separate hospitals).
128
WORLD HEALTH ORGANISATION (WHO), MODEL LIST OF ESSENTIAL MEDICINES, 19TH LIST (Apr. 2015), sec.
22.1, at 38.
129
BFAD Advisory 2002-02. Misoprostol (Cytotec): Unregistered Drug Product, Food and Drug Administration
Philippines (FDA), http://www.fda.gov.ph/advisories/pharmaceutical/38928-bfad-advisory-no-02-02s (last visited
Oct. 14, 2015) [hereinafter BFAD Advisory 2002-02] (The circular has not been withdrawn and is still effective).
See also WHO, Expert Opinion on House Bill 4643 on Abortive Substances and Devices in the Philippines (Nov.
7, 2006) (Misoprostol, a prostaglandin, can be used for other lifesaving purposes such as therapeutic abortion in
cases of missed abortion, intrauterine fetal death, and severe eclampsia, and cervical ripening prior to
obstetrical/gynecological procedures such as therapeutic curettage and insertion of intrauterine devices.).
130
The FDA was then known as the Bureau of Food and Drugs (BFAD).
131
BFAD Advisory 2002-02, supra note 129.
132
See Food, Drug, and Cosmetic Act, Rep. Act No. 3720 (1963) (Phil.); Food and Drug Administration (FDA)
Act of 2009, Rep. Act No. 9711 (2009) (Phil.). The Food, Drug, and Cosmetic Act, sec. 12, as amended by the
Food and Drug Administration (FDA) Act of 2009, provides for imprisonment of one to ten years, fines of up to
500,000 pesos, or both.
133
RPRHA, supra note 8, secs. 4(c), 4(d), 5; IRR, supra note 10, sec. 3.01(y).
134
CEDAW Committee, General Recommendation No. 28 on the core obligations of States parties under article 2
of the Convention on the Elimination of All Forms of Discrimination against Women, paras. 33-34, U.N. Doc.
CEDAW/C/GC/28 (2010) (In respect of article 2(c) of the Convention, States parties must ensure that courts apply
the principle of equality in line with the obligations in the Convention, and women have recourse to affordable,
accessible and timely remedies (with legal aid and assistance as necessary); CEDAW Committee, Gen.
Recommendation No. 24, supra note 60, para. 13, (In respect of article 12 of the Convention, States parties must
ensure that legislation, executive action and policy comply with their obligations as regards equal access to health
care and to ensure effective judicial action.).
135
CEDAW Committee, Inquiry Report, supra note 4, paras. 20, 44─45.
136
Id., para. 51 (j).
137
Id., para. 52 (e), (g).
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