education in school curricula and conduct educational campaigns to raise women's awareness of their reproductive health rights.87 As noted earlier, the number of adolescent pregnancies has doubled in the past decade; this is notwithstanding the Adolescent Health and Youth Program put in place since 2001 to address the health concerns of young people88 and a memorandum issued by the DOH Commission on Population in 2014 providing guidelines aimed at reducing, inter alia, adolescent pregnancies, abortion and gender-based violence through education and dissemination of information on reproductive health rights.89 Further, there are still no guidelines for the age- and developmentappropriate reproductive health education called for under the RPRHA.90 II. Access to Safe and Legal Abortion (Arts. 10(h), 12) Restrictive abortion laws have long been characterized by the Committee as a violation of women’s right to health under Article 12. 91 The Inquiry Report noted “the potentially lifethreatening consequences of unplanned and/or unwanted pregnancies as a direct consequence … of the strict criminalization of abortion without any exemptions provided for in the state party’s legislation,” and found that the failure of the state party “to provide the full range of sexual and reproductive health services, commodities and information resulted in �� unsafe abortions and unnecessary and preventable maternal deaths.”92 In light of these findings, the Inquiry Report called for the amendment of Articles 256 to 259 of the state party's Penal Code to legalize abortion in cases of rape, incest, threats to the life and/or health of the pregnant woman, or serious malformation of the fetus, the decriminalization of all other cases where women undergo abortion, and the adoption of necessary procedural rules to guarantee effective access to legal abortion.93 Abortion is common in the Philippines: data available after the inquiry visit indicates that an estimated 610,000 induced, and potentially unsafe, abortions took place in the Philippines in 2012, an increase from 560,000 in 2008. 94 As acknowledged by the state party, induced abortion is one of the leading causes of maternal deaths in the Philippines,95 and complications resulting from unsafe and illegal abortions are a prominent cause of maternal death in the City of Manila. 96 In fact, an estimated 1,000 maternal deaths were attributed to abortion complications in 2008 97 and, while official state party statistics show that the maternal mortality ratio fell steadily from 1990 to its lowest level in 2006,98 it rose sharply to 221 per 100,000 live births in 2011.99 The inquiry was not the first time the Committee and other UN treaty-monitoring bodies called the attention of the state party to the substantial number of unsafe abortions in the country. In its 2006 Concluding Comments, the Committee raised concern about the high number of deaths resulting from induced abortions 100 and recommended that the State party consider reviewing its laws with a view to removing punitive provisions imposed on women who have abortions. 101 The Committee on Economic, Social and Cultural Rights 102 and the Human Rights Committee103 expressed similar concern and issued recommendations. a. Continued criminalization of abortion The state party has always adopted a narrow interpretation of the constitutional provision that requires the state to “equally protect the life of the mother and the life of the unborn from conception,” 104 making it an outlier in a global context in which countries with similar provisions nevertheless permit abortion on certain grounds.105 The state party has one of the most restrictive abortion laws in the world, imposing a criminal ban on abortion with no clear exceptions, even when a woman’s life or health is in danger, when pregnancy is a result of rape or incest, or in cases of fetal impairment.106 6