conception." This conclusion is objective, consistent with the factual evidence, and independent of any specific ethical, moral, political, or religious view of human life or of human embryos.164 Conclusion: The Moment of Conception is Reckoned from Fertilization In all, whether it be taken from a plain meaning, or understood under medical parlance, and more importantly, following the intention of the Framers of the Constitution, the undeniable conclusion is that a zygote is a human organism and that the life of a new human being commences at a scientifically well-defined moment of conception, that is, upon fertilization. For the above reasons, the Court cannot subscribe to the theory advocated by Hon. Lagman that life begins at implantation.165 According to him, "fertilization and conception are two distinct and successive stages in the reproductive process. They are not identical and synonymous."166 Citing a letter of the WHO, he wrote that "medical authorities confirm that the implantation of the fertilized ovum is the commencement of conception and it is only after implantation that pregnancy can be medically detected."167 This theory of implantation as the beginning of life is devoid of any legal or scientific mooring. It does not pertain to the beginning of life but to the viability of the fetus. The fertilized ovum/zygote is not an inanimate object - it is a living human being complete with DNA and 46 chromosomes.168 Implantation has been conceptualized only for convenience by those who had population control in mind. To adopt it would constitute textual infidelity not only to the RH Law but also to the Constitution. Not surprisingly, even the OSG does not support this position. If such theory would be accepted, it would unnervingly legitimize the utilization of any drug or device that would prevent the implantation of the fetus at the uterine wall. It would be provocative and further aggravate religious-based divisiveness. It would legally permit what the Constitution proscribes - abortion and abortifacients. The RH Law and Abortion The clear and unequivocal intent of the Framers of the 1987 Constitution in protecting the life of the unborn from conception was to prevent the Legislature from enacting a measure legalizing abortion. It was so clear that even the Court cannot interpret it otherwise. This intent of the Framers was captured in the record of the proceedings of the 1986 Constitutional Commission. Commissioner Bernardo Villegas, the principal proponent of the protection of the unborn from conception, explained: The intention .. .is to make sure that there would be no pro-abortion laws ever passed by Congress or any pro-abortion decision passed by the Supreme Court.169 A reading of the RH Law would show that it is in line with this intent and actually proscribes abortion. While the Court has opted not to make any determination, at this stage, when life