refusing to heed Department of Health advise to provide the whole range of family planning commodities in accordance with the RPHRH Law. 38. In her defense, the Mayor of Sorsogon City invokes her right as a ‘conscientious objector’ on the basis of the decision of the Supreme Court in Imbong v. Ochoa,44 which declared the RPRH Law not unconstitutional but voided the provision penalizing public officers who refuse to implement the law, categorizing them as a ‘conscientious objectors.’ 39. Moreover, the criminalization of abortion remains in place, and despite provisions postabortion care (“PAC”), the stigma of abortion affects the availability and adequacy of PAC in health facilities. Information before the Commission reveals that some governme nt hospitals have refused women in need of PAC, while one woman, although given PAC, was arrested and sent to jail after treatment. The submission of EngendeRights and Center for Reproductive Health Rights further elaborates on the issue, showing how the criminalization of abortion has directly impacted the delivery of quality, humane, nonjudgmental PAC as required by law. CRR likewise report the policy against emergency contraceptives and how this adversely affects women survivors of sexual violence. 40. The CHRP has also documented local government units that criminalize and penalize home births. These ordinances, although encouraging facility based delivery, penalize birth attendants and women who give birth at home. The CHRP is concerned with the proliferation of these ordinances, as they impact indigenous women in exercise of their cultural rights, and women in geographically isolated areas, beyond the reach of government health services and facilities. 41. The CHRP Inquiry also documented the implementation of the policy requiring the consent of parents of minors wanting to access reproductive services and minors wanting to be tested for HIV. While not consistently practiced, the CHRP also documented hospitals requiring spousal consent for tubal ligation. 42. The Committee may wish to urge the State Party to report on its strategies in implementing the RPRH Law and the realization of women’s right to reproductive health in view of the foregoing barriers. Specifically, the Committee may wish to urge the State Party to: a) review the effectiveness of decentralization in the delivery of health services and pass the necessary legislation to address the fragmentation of the health delivery system, including review of the Magna Carta for Health professiona ls; b) report on the efforts to address the situation of Sorsogon City (and other local government units similarly situated) and the denial of RH services in the area; c) clarify the scope of the ‘conscientious objector’ and study its impact on the provision of reproductive health services; d) provide information on the efforts of the State Party to ensure quality, humane, non-judgmental post-abortion care; e) issue a policy against the criminalization of home births and instead conduct broad-based consultations with health professionals, traditional birth 44 G.R. No. 204819 (April 8, 2014). Page 9 of 11