Revised Petition for Certiorari vs RH -Final

Republic of the Philippines

S up uprr eme Court ur t Manila

SERV RVE E LIFE CAGAYAN D E ORO CI TY I N C.,repres C.,represente ented d by D R. N ESTO ESTO R B. B. LUM I CAO, CAO , M .D. as Pre President and in his personal personal capaci paci ty, ROSEV RO SEVAL ALE E FOUNDATION INC., represented by DR. ROD RIG O M . ALEN ALEN TON TO N , M D as membe memberr of the school board and in his personal capacity, pacity, ROSEM ROSEM ARI E R. ALEN TO N , IM ELDA G. IBARRA, IBARRA, CP CPA, LOVENI A P. N ACES ACES, Phd Phd..,ANTH ON Y G. N AGA C EARL AN TH ON Y C. GAM GA M BE and, M ARLON ARLON I . YAP Petitioners, - versus – OFFI OFFI CE OF TH E PR PRES ESII D ENT, ENT , SEN ATE OF TH E PH PH I LIP LI PPI N ES, H OU SE OF REPR REPRE ESEN SEN TATI TA TI V ES, ES, H ON . PAQU PAQU IT O N . OCHOA, JR. JR.,, Executive Secretary, H ON . FLORE FLOREN N CIO B. ABAD, Secretary, Deparr tm Depa tme ent of Budget and M ana anage gement; ment; H ON . EN RIQUE T. ONA, Secretary, Department De partment of H ealt h, H ON . ARM IN A. LUISTRO, LUISTRO, Secretary, Deparr tm Depa tme ent of Educati Educati on and and HON. M AN UE UEL L A. ROXAS I I , Secretary, Department of Interior and Local Government Respondents.

G.R. N o ___ .______ ___ ______ ___ ______

For:

CERTIORARI and PROHIBITION wi th a prayer prayer f or a TEM TEM PORARY RESTRAINING ORDERa ORDERand/ or WRIT OF PRELIMINARY IN JUN CTION

x------------------------------------------------------------------------------------------------x

PETITION for for Cer Cer ti or ar i and Pr ohibiti on

A milestone in the history of Philippine legislation did occur with the pass passage of the t he R Re epu publi bli c Act 103 10354 54,, enti enti tl ed “ A n act act Provi Prov i di ng ffor or a N ati ona onall Poli cy on Responsi ponsi ble Pa Parenthood and Repr Reprodu oduc cti ve Heal Heal th” th ” , he hereinafter reinafter refe referr rre ed to t o for brevi brevi ty as the “ RH Law Law”” , as as jubilantl jubi lantly y claim claim ed by the t he proponents thereof. The significance, however, lies not in the law itself but

Peti ti on for Ce Cert rt ior ari & Prohi bition bit ion

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in the vigorous exercise of the freedom of expression and other fundamental rights by all citizens without discrimination. Ironically, the same law strips the people of the very rights massively rousedby the process of its creation. The foregoing is merely a sampling of the many transgressions upon the dignity of the human being which the RH Law imposes. Worth mentionin menti oning g at at the t he outset outset i s a devi ousl ousl y hi dd en fl oodgate oodgate f or abort abortii faci faci ents in an innocuous provision, which, upon some reflection, reveals that the RH l aw effe ff ecti vely sancti ncti ons the taking takin g of th the e most most basi basi c of all ri ghts, the right ri ght to to life.

T he Case Case& N at ur e of t he Pr ocee ceedi ng

Peti ti one oners, rs, throu th rough gh counse counsel s,

come be befor fore e thi th i s M ost ost Honor H onora able bl e,

Independent and Impartial Court of Last Resort, by way of Petition for Certiorari and Prohibition with prayer for the issuance of a Temporary Restra tr aini ng Order and/ and/ or Wr i t of Pre Prelili mi na nary ry Injunc Inju ncti ti on aga agaii nst nst the Offi ce of the President of the Republic of the Philippines and its instrumentalities under Rule 65 of the Rules of Court seeking to annul the passage and prohibit the implementation of Republic Act No. 10354for having been ena nac cted w i th grave abuse abuse of di d i scretion reti on amou amounti nti ng to t o la l ack and/ or exce excess of juri ju ri sdi cti on.This on.Thi s pe p eti ti on i s fi f i l ed as an ori or i ginal gi nal speci peci al civ i l acti acti on be bec cause ause there is no remedy of appeal from the acts of Congress and the President. Neither is there any other plain, speedy and adequate remedy available to petitioners in the ordinary course of law.

T he Part ies ies The Petitioners:

A) Corporate/Institutional Petitioners


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SERVE LIFE CDO INC.,hereinafter INC., hereinafter referred to as “PetitionerServe Li fe” i s a non-stoc non-stock, k, non-prof non-p rofii t corpor ati on, du dull y organized organized i n accorda ord ance with Philippine laws as shown by the Certificate of Registration issued by the th e Securi cur i t i es and Exchange Exchange Commi Comm i ssi on beari beari ng N o. CN 20 2006 0628 2887 876 6 d ated August 31, 2006, a photocopy of which is hereto integrally attached as A nne nnex x “ A ” w it h pri nci nci pa pall pl ace of busi busi ne nes ss at 2/ 2/ F Borromeo Bui ld ing, D aomar St St r eet , Cagayan Cagayan de Oro Or o Cit Ci t y w here it may be b e ser v ed pr p r oces ocesses of the th e H onorable onorabl e Su pr eme Court, Cour t, repr esente nt ed herei herei n

by i ts Presi resi dent

D r.

N estor B. Lu Lumi mi cao ao,, M.D.as M .D.as show n by the th e Corporate Corp orate Se Secretary cretary ’s Cert Cert i fi cate of Board Resolution dated January 12, 2013, a photocopy of which is hereto i nte nt egra gr al l y attac att ached hed as as A nnex “ B” .Pe .Peti ti oner Se Serv e Li fe Cd Cd o, Inc. In c.ii s comp compos ose ed of a group gr oup of

pr ofess ofessi onals i .e. .e. doctors doctor s, l aw awyers, yers, edu duc cators, soci oci ologi ol ogis sts,

busines businessmen & some pri ests & reli gious giou s who wh o organized the t hemse msell v es for t he Protecti rotecti on of Li fe, i n Defe Defens nse e of the fami l y and the sancti ncti ty of marri marr i age and the t he promoti pr omoti on of of authenti c he hea al th.

Peti ti one onerr ROSEVA OSEVA LE FOUN DA TION I N C., C., he hereinafter reinafter referr referre ed t o as “ Peti ti one onerr Ros Rosevale” i sa non-st non-st ock ock and non-pr ofit ofi t found f ounda ati on dul du l y organized and existing under Philippine lawsas shown by the Certificate of Regis gi str ation ati on is i ssued by the th e Securi ti es and Exchange Exchange Comm Commii ssi on beari bearing ng N o. H N 09 095-2 5-22 27 dated A u gust 30, 30, 199 1995, 5, a photoc phot ocopy opy of w hi ch is i s hereto hereto i nte nt egra gr al l y atta tt ache hed d as A nne nnex x “ C” . It operate operates s an edu edu cati ona onall i nsti nsti tuti tu ti on know n in i n the commun omm unii ty as ROSE ROSEVA LE SCH SCH OOL cateri cateri ng to preparator p reparatory, y, grade sc school and high school levels, located at Xavier Estates Phase IV, Fr. William Masterson SJ Avenue, Airport Road, Cagayan de Oro City, where it may be serv ed pr oce ocesses of the th e Honor H onorable able Su Su pr eme Court Cour t .Pe .Peti ti one onerr Ro Ros sev al e thr th r u Rose osev al e Schooli n clos cl ose e coll coll aboration borati on w i t h pare p arents nts aims to provi pr ovi de holi sti c, relev relev ant and exemp xempll ary academic, demi c, pr ofe ofes ssi ona onall and pe persona rsonall formati for mation on for the students, parents and teachers to enable them to live a virtuous and happy life. It is represented herein by a member of the foundation and


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school board namely: Dr. Rodrigo M. Alentonas shown by the Corporate Secretary’s Certificate of Board Resolution dated January 12, 2013, a photoc phot ocopy opy of w hic hi ch is he hereto reto integral integral l y attache attached d as A nne nnex x “ D” .

B) Individual Petitioners

Petitioners are Filipinos, medical practitioners and health professionals, members of the Philippine Bar, educators and various professionals. They file this petition as citizens of the “Republic of the Philippines” whose sworn duty is to uphold , “support and defend its Constitution xxx .” They also file this petition as parents and as a class suit in representation of other parents and individuals similarly situated. As parents and professionals, the RH Law Law hits petitioners as oppressive, unjust and confiscatory thus, unconstitutional. Petitioners are devout and practising Catholics whose religious beliefs find the mandatory provisions of the RH Law obnoxious and unconscionable. They are, namely: namely :

Petitioner DR. NESTOR B. LUMICAO, MD, is a Filipino, of legal age, married and a resident of BorromeoCorrales Extension, Cagayan de Oro Cit yw he herr e he may be se serv ed proce p roces sses of thi t hi s H onorable onorabl e Court.H Cour t.H e i s a medical practitioner in Cagayan de Oro City specializing in Pediatric Sur ge gery ry.. He li kewi kew i se fi l es thi s petiti petit i on in hi s persona personall capac capacii ty. ty .

Peti ti one onerr D R. RODRIG RODRIGO“ O“ ROD” M . ALENTON A LENTON , Fil Fil ip ino, of lega legal age ge,, married and a resident of Aluba Subdivision, Cagayan de Oro Citywhere he may be b e serv ed pr oce ocesses of thi t hi s Honor H onorable able Cour Cour t.H e i s a med med i cal practi practi ti one onerr in Ca Caga gayan yan de Oro Cit y w ho spe spec ciali zes zes i n Card Cardiol iol ogy and w ho likewise joins in the petition in his personal capacity together with his wife ROSEMA OSEMA RIE R. A LENTON LEN TON .


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Petitioner DR. LOVENIA P. NACES, Filipino, of legal age, married and a re r esi d ent of C28 C28,, Block 17, P.N P.N . RoaS RoaSu u bd bd.,Ca .,Call aa aanan, nan, Cagay Cagay an de d e Oro Cit yw he herr e she may be se serv ed proc pr oce esses of thi t hi s H onorable Court. Cour t.

Petitioner IMELDA G. IBARRA,CPA, Filipino, of legal age, married and a resident of Lot 10, Block 7, Reyes Subd., Bugo, Cagayan de Oro Cit yw he herr e she may be serv ed proc pr oce esses of thi t hi s H Honorable onorable Court. Cour t.

Peti ti one onerr A N THON TH ONY Y G. N A GAC, GA C, Fil i pino, pi no, of lega legal age ge,, marr marrii ed and a res resi dent of Lot 12 12,, Bl Bl ock ock 30 30,, Phas Phase e 2, N H A , Kauswaga Kausw agan, n, Cagayan Cagayan de d e Oro Cit yw he herr e he ma may y be se ser v ed proce p roces sses of thi t hi s H onora onor able bl e Court. Cour t.

Petitioner EARL ANTHONY C. GAMBE, Filipino, of legal age, married and a resident of Mandumol, Upper Macasandig, Cagayan de Oro Cit yw he herr e he may be serv ed proce p roces sses of thi t hi s H onorable onorabl e Court. Cour t.

Petitioner MARLON I. YAP, Filipino, of legal age, married and a resident of Lot 39, Block 15, Westfield Subd.,Iponan, Cagayan de Oro Cit yw he herr e he ma may y be se serv ed proce p roces sses of thi t hi s H onorable onor able Court. Cour t.

T he Res Respondents: pondents:

Respondents herein are :

The OFFI OFFI CE OF TH E PRE PRES SI DEN T, Malaca M alacanang nang Pal Pal ace, ace, M anil ani l a;the SEN ENA A TE OF THE TH E PH PH IL IPPIN IPPIN ES, GSIS Complex, RoxasBlvd., Pasay City; and the HOUSE OF REPRESENTATIVES, Batasan Hills, Quezon City which are impleaded for passing and approving the law in question.


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HON. PAQUITO N. OCHOA, JR., Executive Secretary, Office of the President of the Philippines, Malacanang Palace, Manila; HON. FLORENCIO B. ABAD, Secretary, Department of Budget and Management (DBM), Malacanang Pal ace ace, Ma M anil ni l a; HON H ON.. EN EN RIQU E T. T. ONA ON A , Se Secretary, De D epartment part ment of H eal th (D OH ), San Lazaro Compound, Cityy of Manila; HON. ARMIN A. LUISTRO, FSC, Secretary, Department of Education (DepEd), DepEd Complex, Meralco Avenue, Pasig City; and HON. MANUEL A. ROXAS II, Secretary, Department of Interior and Local Government (DILG) EDSA, cor. Mapagmahal St., Diliman, Quezon City; they are are al l publ p ubl i c off offii ci al s i n-charge n-charge of the enforce nf orcement ment and and admi nis ni str ati on of of the Act and all laws relative to the conduct of their respective duties and functions; for these reasons, respondents are being sued herein in their official capacities and may be served summons and other processes at their respective offices as above indicated and through their statutory counsel, the Solicitor General, at 139 Amorsolo Street, Legaspi Village, Makati City.

State Stateme ment nt of M ater ter ial D ates tes

The RH RH Bil l w as si gned i nto nt o Law L aw on D ecember 21, 21, 201 2012 2. Thus Thu s, petitioners have sixty days or until February 19, 2011 w ithin w hich hich to fil e this petition. Accordingly, this Petition filed on January 15, 2013 with the docket and other other l aw ful fu l fee fees s having havi ng bee been ful f ul l y pa p ai d on tthe he same date i s ti mely.

T he A nt ecede cedent nt s and and Pr eli mi nary Conce Concer ns

Civic involvement in a legislative act reached a record high in the passage of the RH Law. Almost every Filipino was aware of the law and more often than not, he or she has strong opinions about its effects. No one appears to have taken the middle ground and everyone freely expressed their stance tance from fr om the th ei r ow n va v antage point. poi nt.


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A vast range of concerns were thus thrown in the open. This ranged from fr om i ssues ba bas sed on p pur ure el y subjecti ubjecti v e cl cl ai ms of mor al sup upe eri ori ty by reas reason of spiritual convictions to nightmarish speculations of a rising totalitarian. Rational

discussion

und erp ri v i l ege ged d

and

beca became

information

frequent frequent

dissemination

w hic hi ch

w as

among

accomp companied anied

by

the a

corresponding increase in the frequency of name calling and crying in the hall ow owe ed hall s of the t he S Se enate. While it is indeed exhilarating to see democracy at its best, excessive zeal and fervor, misplaced rationality and of course the name calling made many of those involved lose sight of what truly matters in the passage of a law. It was forgotten that the one true yardstick in determining the accepta pt abil i ty of a l aw i s the Cons Consti ti t uti ut i on.

Consequently, it came as no surprise why both the House of Representatives and Senate of the Philippines signified their approval of and the th e Off i ce of the t he Pres Presii dent signe sign ed the th e RH Bi l l i nto nt o law on De D ecember 21,2 21,201 012, 2, despite serious, patent and unmistakable constitutional flaws which should hav ha v e made a reas reasona onably bly caut i ous and and pru pr u dent ma m an ta t ake another another l ook at t he bil l and his fund ame mental ntal law. law . It took the advocates and their predecessors fourteen years to finally have a purported Reproductive Health Law. While their determination is l aud uda able, their efforts effor ts must must fa f ai l.

Petitioners hasten to add that the failure is not due to some subjective or religious moral high ground liberally sprinkled with fear of hell. RA si mp mpll y fa f ai l s to pass pass the tes test of consti consti tuti tu tiona onall i ty. ty .

Gr oun ds for for the Gr ant of t he Peti Peti ti on


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It i s humbly hum bly pos p osit it ed tha t hatt -

1. The H ouse of Repr Repre esentativ entati v es, for appr app r ovi ov i ng H B N o.4 o.42 244 d espi te obvi ous, ous, pa patent tent and and u nmi stakabl takabl e consti onsti tuti tu ti ona onall fl aw s, 2. The Senate of the Philippines, for approving HB No. 4244 despite obvi ous, ous, pa patent tent and and u nmi stakabl takabl e consti onsti tuti tu ti ona onall fl aw s, 3. Offi Off i ce of the Presi resi dent, for si si gning gni ng H B4244 N o. i nto Repu publi bli c A ct N o. 10354, despite obvious, patent and unmistakable constitutional flaws,

Gravely abused their discretion in a manner tantamount to lack or exces xcess of ju ri sdi cti on.

4. Consequently, and in addition to the great damage and prejudice pose posed by the law, law , res responde pond ents HON H ON . FLORE FLOREN N CIO B. A BA D, Secretary retary , Depart Department ment of Bud ge gett and M ana anage gement; ment; H ON. ON . EN EN RIQU E T. ONA, Secretary, Department of Health, HON. ARMIN A. LUISTRO, Secretary, Department of Education and HON. MANUEL A.

ROXAS

II,

Secretary,

Department

of

Interior

and

Local

Government must be enjoined from implementing the law.

Issues

Respondents’ abuse discretion is best illustrated by showing that they have pass passed an unm u nmii stakably takabl y i l l egal enactment. enactment. H ence, nce, the th e core core questi questi on for f or determination is:

Whether the RH Law is unconstitutional.


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D i scussion cussion

As previously mentioned, concerns, extraneous to the passing of a l aw , bec became the focus focus of many deli be berati rations ons on the th e RH Law Law.. Consti Consti tuti tu ti ona onall i nfi rmi rm i ti es have thu thus s ri dd l ed the t he sai d l aw . Thes These are as as foll fol l ow ows s.

For clarity, the more significant constitutional infirmities shall be pre pr esented herei herei n i n the t he o ord rde er pr esented u nder the t he RH RH Law Law..

I.

The Ri ght to Li fe

A s i t so so happ happe ens, ns, the most most i mp mportant ortant r i ght of all i s one of the th e v ery fi rst fatal fat al l apse apse of the t he R.A R.A.. N o. 1035 10354. 4. Som Some e dis di scer cer nm nme ent m ay be nece necessary inasmuch as the same has been cleverly couched in very minimalist language amidst a deluge of not so subliminal attempts to desensitize. To start , Se Secti on 2 of RH i n pa p ar t states: tates:

SEC. 2. 2. De D eclarati on of Pol Pol icy. icy . – xxx

xxx

xxx

xxx

The State likewise guarantees universal access to medically-safe, non- abortifacient, effective, legal, affordable, and quality reproductive health care services, methods, devices, supplies which do not prevent the implantation of a fertilized ovum as determined by the Food and Drug Administration (FDA) and relevant information and education thereon according to the priority needs of women, children and other underprivileged sectors, giving preferential access to those identified through the National Household Targeting System for Poverty Reduction (NHTS-PR) and other government measures of identifying margi nalizati on, who shall shall be v oluntary olun tary bene benefi fi ciari ciari es of re r eproducti pr oductive ve health health care, care, services and supplies for free.

Whi Wh i l e Se Secti on 4 de d efi nes aborti bort i faci faci ents nt s as as:

SEC. 4. Definition of Terms. – For the purpose of this Act, the following terms shall be defined as follows:


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(a) Abortifacient refers to any drug or device that induces abortion or the destruction of a fetus inside the mother’s womb or the prevention of the fertilized ovum to reach and be im planted planted in t he mother’ mother’ s womb upon d etermination of t he FDA .

Taken together, the assurance of access to non-abortifacient devices and supplies, viewed from a purely secular vantage, appears innocuous and actually laudable. The framers of RH are apparently aware of this. Hence, the law has be bee en gene generou rous sl y peppered peppered w i th the t he w ords ord s “ access” and “ nonabortifac borti facient. ient.”” A nd many w ere fooled. fooled.

In one innocuous section buried among all the rhetorics, the actual danger danger of the th e devi ces ces and sup suppl pl i es to be made av av ail able i s evi dent. dent . Section 9 of RH RH provi de des s:

SEC. 9. The Phili ppine N ational D ru g Form Form ulary Syste System m and Famil Famil y Planni ng Supplies Supplies. – The National Drug Formulary shall include hormonal contraceptives, intrauterine devices, injectables and other safe, legal, non-abortifacient and effective family planning products and suppl ies. ies. The Phil Phil ippi ip pine ne Nati ona onall Drug Dr ug Formu lary System (PN (PN DFS) DFS) shall shall be obse observ ed in selecting drugs including family planning supplies that will be included or removed from the Essential Drugs List (EDL) in accordance with existing practice and in consul consultati tation on w it h reputab reput able le medi medi cal cal assoc ssociati iati ons in the Phil Phil ip pine pi nes. s. For the purpose of this Act, any product or supply included or to be included in the EDL must have a certification from the FDA that said product and supply is made available on the condition that it is not t o be used used as an aborti facient. These products and supplies shall also be included in the regular purchase of essential medicines and supplies of all national hospitals: Provided, further, That the foregoing offices shall not purchase or acquire by any means emergency contraceptive pills, postcoit postcoit al pil ls, abortif acients acients t hat w il l be used used for suc such h purpose purpose and their other forms or equivalent.

The implications are staggering. In effect, the RH authorizes the Government to procure and distribute supplies unceasingly marketed as non-abortifacients by the law when in truth and in fact, the said supplies have abortifacient properties.

True Tr ue there is the cave caveat at that the th e aborti bort i faci faci ents nt s w wii l l not be u sed as such . But giv en the t he scope of of how these these wi l l be made av av ai l able, there i s no w ay t his hi s can be enforc nfor ced at all. all . Its aki aki n to giv gi v i ng a chil hi l d hi s or her favori te ca candy w i th


Page Page 11 of 26

the caveat that it is only to be used as a toy or giving a knife to your mortal ene nemy my w i th the ca cav eat of not stabbing stabbing you i n the t he ba back. Tru l y, no responsibl responsible e pare pa rent nt or pe p erson rson w ould do such such a thi ng. And A nd yet yet the Law Law not ju st authorize ut horizes s thi s i t re r equi res the governm governm ent t o commi commi t such such a stu stupi pi d atroc atr ocii ty on the sc scal e of mil li on ons s.

Even more bothering is the fact that the hidden meaning of nonabortifacients, which basically states it could be an abortifacient, was so cl ev erl y done it could oul d only have be bee en de d eli be berate rate.. The sai d quali fi cati on coul could d hav ha v e ea easi l y be bee en stated stated under un der the t he de defi fi niti ni ti on of t erms rm s where the publi publ i c ca can be fully apprised. Apparently, using the previous analogy and under the assumption that the giving of candy to the child was no stupid mistake, it w ould oul d be l i ke gi gi v i ng a chil hi l d cyani cyanide de lace laced candy candy then giv i ng the appearanc appearance e of respons responsii bil it y by sa sayi ng don’t eat i t but nevert neverthe heles less s hoping t he chil d w il l eat the t he candy i nasmu nasmu ch as as that th at w oul d be one m out outh h le l ess to fe f eed and d rain rai n the th e res resource our ces s. Thi s is ev ev en more m ore al al arm i ng.

Moreover, the fact that these supplies may be abortifacient is a detail w hic hi ch must m ust be di scl ose osed. RH has v ery cl ear pr ovi si ons on a ful l di scl osur osure e of family planning methods without qualification otherwise criminal penalties are in order. Hence, information on abortion, which is controversial but is nev ne v erthe rt hell ess a famil fami l y pl anni ng method method cannot be w i thheld. thheld . This w ould oul d include

Regardless of the motive which can only be subject to speculation, the ultimate conclusion remains the same - RH is definitely anti-life cleverly disguised as an enhancement to womens rights and masked as a great step tow ard s l i be berali rali ty. ty . This l aw i s desi desi gne gned d for f or genoc genocii de!


Page Page 12 of 26

Given the foregoing, no doubt exists at this early a point that it vi olates olates Secti on 1 12 2, A Art rtii cl e of th the e Co Cons nsti ti tuti tu tion on w hic hi ch prov p rovii des: des:

SECTION SECTION 12. xxx It (the state) shall equ equ ally pr ote otect ct the l ife of of t he mother and the life of of the un born born from conce conception. xxx

II.

The right t o protecti protecti on against Hazardous products……

The 1987 Consti Consti tuti tu ti on, i n Art A rtii cl e XVI, XVI , Secti on 9 pr ovi des and w e quote: Section 9. The State shall protect consumers from trade malp rac racti ti ce ces s and from fr om substa substandard ndard or hazard hazard ous pr oducts” .

A ga gaii n, the above-q bove-quoted uoted Cons Consti ti tu tuti ti ona onall prov p rovii so str str esses on the i mp mport orta ance of pr prote otec cti on to l if e and is co congruent ngruent to “ the ri ght to li fe” . Be that as it may, an International Agency for Research on Cancer (IARC) Study (2011) by 23 Scientists fr om 10 count ountri ri es conc oncll ud ude ed

that “ oral combi combine ned d es estr troge ogen-pr n-pr oge oges stoge togen n

contr ontrac ace ept ptii ves ar e carci rcinoge nogeni nic c to humans hu mans.. The sai d study stud y me m enti ons that “ oral comb co mbii ned es estr oge ogen-p n-prr oge oges stogen contr contr ac ace ept ptii v es ca cause use ca cance ncerr of th the e br bre eas ast, t, i n-sit n-situ u and i nv nva asi ve cance ncerr of the ut ute er i ne cerv rvii x, and cance cancerr of the th e l i ver.” It cannot cannot be gaii ns ga nsaid aid as i t has be bee en dul d uly y establi establi she hed d by sci enti fi c stu studi di es that contr contr ac ace ept ptii ves are haz haza ar dous to w ome omen, n, yet, the RH Law all ots bi billll i ons of taxpayers taxpayers’’ money for the pu purr chas hase e of the contr ontra acept ptii ves to be di str i but bute ed part partii cul ularl arly y to the poor. On thi s score al one one,, the RH Law i s al r eady uncons unconsti ti tu tuti ti ona onall . Trea Treatm tme ent for f or canc cance er i s very expensive even if it is not always curative but mostly just palliative. What is ev en mor e tr agic is th that at when w hen these these poor w omen get get sick of cance cancerr s, there i s no free treatment available from the government. More and more women are getting sick of different kinds of cancers because of oral contraceptive pillsthat they thems the mse el ves pe perso rsona nall ly buy for the their ir own us use e, wi w i th the abundant abundant f ree supp uppll y fr om the state, it would not be farfetched to expect a deluge of cancer patients.


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I I I . I nvoluntary nvoluntary Se Servit ud ude e

In simplest terms involuntary servitude is slavery. This state of being has be bee en aboli she hed d i n the t he Uni ted States States by t he 13th 13th amendme amendm ent m ore than a century ago. It has been outlawed by the community of nations for being degrading and inhuman. The magnitude of this restraint on freedom is so abhorrent to appoint that any form of slavery is almost always ended by revolution with many of the oppressed opting for the freedom of death. It thus thu s cl ose osel y r iv al s the imp ortance ortance of the ri ght to l if e. A nd now, iitt i s be being ing reint roduc rodu ced by RH.

Sect ect i on 17 of RH st ates: ates:

SEC. 17. Pro Bono Services for Indigent Women. – Private and nongovernment reproductive healthcare service providers including, but not limited to, gynecologists and obstetricians, are encouraged to provide at least forty-eight (48) hours annually of reproductive health services, ranging from providing information and education to rendering renderi ng medical serv serv ices, ices, fr ee of charge to i ndi gent gent and low -income patients as as ide id enti fi ed through the NHTS-PR and other government measures of identifying marginalization, especially to pregnant adolescents. The forty-eight (48) hours annual pro bono services shall be included as a prerequisite in the accreditation under the PhilHealth.

A ga gain in ski skillll ful ly veil veil ed und er the t he term term “ encoura ncourage ged,” d,” it w ould seem like the services to be rendered is voluntary. The last sentence, how ev er, i nd ndii cates cates that th at iitt i s not the th e case ase.

Nowadays, a PhilHealth accreditation spells the difference between success and stagnation of medical practice. It is common knowledge how a vast number of patients are either compulsory PhilHealth members by reason of mandatory law or voluntary members thereof. The rest are dependents. And considering the amounts saved on medical bills, PhilHealth accredited providers are chosen in almost all instances given half the chance. Considering further that almost all doctors are Philhealth


Page Page 14 of 26

Accredited, lack thereof would mean omission as a choice of being the provider unless an the provider already has an established name.

It is practically a punitive measure through economic means which prohibits a doctor from engaging in a viable or at least lucrative practice unl ess he or she she gives gi ves 48 hours hour s of w ork w i thout thou t pay. It i s sti l l f orced orced l abor i n disguise.

It may be argued that rule is justified by rendering of service to the less privileged. Fortunately, this right is so precious the constitution only al low s two tw o i nstanc nstance es where where inv olunt ary serv it ud ude e is justi justi fie fi ed, viz:

Article II. xxx xxx

xxx

SECTION SECTION 4. The pri me du ty of th e the people. The Government may call and, in the fulfillment thereof, all conditions provided by law, to render

xxx

Government Government i s to serve serve and protect upon the people to defend the State citizens may be required, under personal military or civil service.

an d

xxx

Arti cle III. xxx xxx

xxx

xxx

xxx

xxx

SECTION SECTION 18

(2) No in volunt ary servit servit ude in any any form shall exist except xcept as a punishment for a crime whereof the party shall have been duly convicted.

Summarized, the two exceptions are 1) Military service; and 2) Conviction of a crime. These exceptions are justified by no less than the preservation of the state against actual existing danger. Compared to this most compelling reason to restrict private rights, the mandate of RH to render compulsory service for the sake of reproductive health pales to shameful shade.


Page Page 15 of 26

In short, the RH bill is justifying instead of protecting the people from slavery with its ludicrously less compelling and completely ignorable duty of promoting public health.

I V. Equal Equal prot ecti on of of the la w s

As if slavery is not grave enough, Section 17 further denies the equal prote pr otec cti on of of the l aw s to repr reprodu oduc cti v e he hea al th care care provi pr ovi ders. ders. RH mentions menti ons “ pri vate and nongove nongoverr nm ent r eproducti ve he healt hca hcar e ser vi ce provi der der s in cludi ng, but not limited to, gynecologists and obstetricians,” as the ones inescapably “ encour ncoura age ged d ” to pr ovi de force forced se serv i ces. Fa Fai l ur e i s penal penal i zed zed w i th nonrenewal of Philhealth accreditation. Thus, Petitioners herein who are nonobgyn medical doctors may be compelled to render annual forty-eight (48) hours annual pro bono services shall be included as a prerequisite in the accreditation under the PhilHealth, lest they lose their PhilHealth accreditation.

Of course this does not immediately mean the equal protection clause has been violated. After all, at its most basic, the equal protection clause is against undue favor of an individual or class privilege, as well as hostile discrimination; it does not demand absolute equality. The fundamental guarante guarant ee i s not br eached ched by a l aw w hi ch appl i es only onl y tto o those persons persons falling within a specified class, if it applies alike to all persons within such class and provided further that there is a substantial distinction between those who fall within such class and those who do not. 1The term 1

[G.R. No. No. 159883. March 31, 2008.] 2008.] DR. PEDRO F. GOBENCIONG, petitioner, vs. HON. COURT OF APPEALS, DEPUTY OMBUDSMAN (VISAYAS), REGIONAL DIRECTOR of the Department of Health, Region VIII, and FLORA DELA PEÑA, respondents. [G.R. No. No. 168059. March 31, 2008.] OFFICE OF THE OMBUDSMAN, petitioner, vs. DR. PEDRO F. GOBENCIONG and the HON. COURT OF APPEALS (CEBU CITY), respondents.


Page Page 16 of 26

“ substantial ubstantial di sti ncti ncti on” is furt he herr quali fi ed by t he requi require reme ment nt that it should be based on real differences and that it must be germane to the purp pu rpos ose es of tthe he l aw .

With the guidance of the foregoing, however, the unequal treatment of the RH on reproductive healthcare providers becomes even more apparent.

Ordinarily, it is very possible for substantial distinctions to exist betw be tw een th the e di ffe ff erent me m edi cal di sci pl i ne nes s. In th thii s i nstanc nstance e, how ever, ul ti mate purpose of RH and other health laws is the promotion of public health in general not only reproductive health. Reproductive health is just a newly introduced facet of public health. In fact, RH recognizes its integration into public health policies. And although reproductive health is not the least i mp mport orta ant aspe pec ct of publ p ubl i c he hea al th i t i s al so not the t he most most i mp mportant. ortant. There There are are other more urgent concerns like the prevention of communicable diseases and halting the spread of fatal ones. There is the lack of the truly essential medic medi ci ne nes s l i ke anti -bioti cs, anti -hype -hyp erte rt ensi nsi v e , vi tamin, tami n, and the l i ke.

In sum, the field of reproductive health has no real difference from other fields considering the overall purpose of benefiting public health. There is therefore no reason substantial difference and reproductive health professionals should not be subjected to the onerous burden under Section 17 simply by reason of their chosen field.

V . Free Fr eedom dom of speec peech a nd of o f expression expression

[G.R. No. No. 173212. March 31, 2008.] DR. PEDRO F. GOBENCIONG, petitioner, vs. DEPUTY OMBUDSMAN (VISAYAS), REGIONAL DIRECTOR of the Department of Health, Region VIII, and FLORA DELA PEÑA, respondents.


Page Page 17 of 26

Section 4 of the Bill of Rights prohibits the passage of laws abridging the th e fre fr eedom of spee peec ch and of expr essi on. Of cours our se there are are w el l r ecognize ogni zed d exce xcepti pt i ons such as as the ri ght to p pri ri v acy and poli pol i ce power. A ga gaii n th the e comm common on denominator of these exceptions is their being just as compelling, fu nd ndame ament ntal al and establi tabl i shed as the th e right ri ght of f ree spee peec ch.

But RH provid prov id es SEC. 23. Prohibited Acts. – The following acts are prohibited: (a) Any health care service provider, whether public or private, who shall: (1) Knowingly withhold information or restrict the dissemination thereof, and/or intentionally provide incorrect information regarding programs and services on reproductive health including the right to informed choice and access t o a full range of legal, medically-safe, non-abortifacient and effective family planni ng method methods s ;

Providers are once again victimized herein by being enjoined under pain of fine and imprisonment to enumerate and withhold nothing on famil y pla pl anning m ethods. thods. Defi Defi nit el y, the so so ca call ed ri ght to t o be informe inf ormed d of all family

planning

methods

hardly

matches

the

relevance

of

the

aforementioned exceptions to free speech. Nor are these methods as established.

It mu mus st be remembe remembered red that f ami l y pl p l anni ng m me ethods thod s, es espe pec ci al l y those those involving medication, are subject to a wide range of conflicting data. Empirical evidence from some exists justifying a method while similar studies show evidence showing otherwise. This is particularly true with arti rt i fi cial me methods thods..

Understandably, the opinions espousing one method while dimissing the other as fraught with too much fatalaties are varied. It would be near


Page Page 18 of 26

impossible to determine which is correct considering that the people best sui ted to judge ju dge are the v ery peo peopl pl e w ho gav gav e the confl conflii cti ng opini opi nions ons..

Consequently, aside from hardly qualifying as a compelling reason to restrict the freedom of speech and expression, perceived violations of Section 23, a, 1 could hardly be determined true beyond reasonable doubt. Thus, healthcare providers should be given the leeway to recommend and/ or omit to mention mention famil y pl anning methods methods they they d eem w ise ise and/ or unsafe.

VI . Econo Economic mic Pol icy

It is undeniable undeniable and and actua tu al ly adm dmit it ted ted t ha hatt t he ul ti mate goa goall of RH RH is econom conomii c pros pr osperi peri t y as seen in i n Se Section cti on 6, aa aa of of t he law . It seeks t o achi achie ev e this by population control. It is amazing how this mode got preferential atte tt enti on despi despi te A Art rtii cl e XII, XII , Se Secti on 1 of the cons consti ti tuti tu ti on w hic hi ch states states -

SECTION 1. The goals of the national economy are a more equitable distribution of opportunities, income, and wealth; a sustained increase in the amount of goods and services produced by the nation for the benefit of the people; and an expanding productivity as the key to raising the quality of life for all, especially the underprivileged. The State shall promote industrialization and full employment based on sound agricultural development and agrarian reform, through industries that make full and efficient use of human and natural resources, and which are competitive in both domestic and foreign markets. However, the State shall protect Filipino enterprises against unfair foreign competition and trade practices. In the pursuit of these goals, all sectors of the economy and all regions of the country shall be given optimum opportunity to develop. Private enterprises, including corporations, cooperatives, and similar collective organizations, shall be encouraged to broaden broad en the base of their ownership. The constitution is clear. Economic objectives are to be pursued through economic policies. Health, much less reproductive health, is not


Page Page 19 of 26

even mentioned. True, this argument may seem tenous at best but it gains relevance w hen consid conside er i ng Se Secti on 22 of of the th e sa same A rt i cle whi w hi ch states states -

SECTION 22. Acts which circumvent or negate any of the provisions of this Article shall be considered inimical to the national interest and subject to criminal and civil sanctions, as may be provided by law. VI I . U nw arrant ed I nterfe nterfere renc ncee in Educat Educat ion

ARTICLE XIV of the Constitution on Education, Science and Technology, Arts, Culture, and Sports in part states: Education (2) (2) They shall shall inculca in culcate te patr iotism iot ism and nati onalism, foster foster lov e of humanity, respect for human rights, appreciation of the role of national heroes in the historical development of the country, teach the rights and duties of citizenship, strengthen ethical and spiritual values, develop moral character and personal personal di scip scip li ne, ne, enco encour ur age age crit ical ical and crea creati v e thi nkin nk ing, g, broaden broaden sc scienti fi c and technol technologica ogicall know kn owledge ledge,, and and p romote rom ote vocational vocational effi ciency.

By the use of the word shall, forced inculcation can only refer to the subjects enumerated above. Forced insertion into the curriculum of sex education has no constitutional basis.

M ore im porta port antly, ntl y, thi s tamperi tamperi ng of w ha hatt to teac teach is i s an i nfra nfr acti on of a less less know know n ye y et equa quallll y potent potent consti onsti tuti tu ti ona onall ri ght of edu duc cati ona onall instit uti ons to self determination. This right can easily be gleaned from another provi pr ovi sion u nde nderr A rticle rt icle XIV XIV w hich state states s:

SECTION 4. (1) The State recognizes the complementary roles of public and private institutions in the educational system and shall exercise reasonable supervision and regulation of all educational educat ional institutions. institutions. The control and administration of educational institutions shall be vested in citizens of the Philippines.


Page Page 20 of 26

Shown herein is the right of the people to control and administer educational institutions which includes the determination of what to teach i n add add i ti on to subjec subjects ts mand manda atori tor i l y re r equi red by t he Consti Consti tuti tu ti on. The The State i s merel merel y l i mited mi ted to reas reasona onabl ble e sup upe erv i si on and and r egul ati on.

Yet, RH mandatorily imposes the teaching of sex education in schools. This is clearly an act of control expressly made unconstitutional by the previously m enti one oned d pr ovis ovi sion

Repub Republi li c Act 10354 10354,, enti enti tl ed “An a ct Pr oviding for for a N at ional Poli cy on R esponsibl ponsibl e Pa rent rent hood and R eproduct product iv e H eal th, a mi snomer, nomer, a deception! By and large, large, as shown above, the RH Law is a sham. Instead of health it brings disease, instead of harmony it brings discord in the family. In making maki ng se sexual and and re r eprodu pr oduc cti ve ri ghts a l ega gall and demandable demandable ri ght for young youn g chi chill dr en and mi nors, rather than bei bei ng res responsi ponsi ble, i t makes parents parents abdic bdi cate the their ir consti onsti tuti tu ti ona onallll y enshri enshri ne ned d pri mary r ole i n the t he rea reari ng of of the their ir children and thus making them vulnerable to the whims & caprices of the state.

In sum, all the foregoing constitutional lapses taken together with the much discussed breaches, such as the separation of church state, are too numerous and obvious to have escaped the attention of respondents. They thus thu s gravely gravely abuse abused the t heir ir di screti reti on in k now nowingl ingl y and acti acti vely pa part rticipating icipating i n the t he pass passage of RH. RH . It i s thu s i ncumbent ncumbent that tto o dec decl are RH RH a v oid l aw not only for being unconstitutional but also for lack of authority on the part of thos th ose e who wh o pas p ass sed i t. A ll egati gati ons in Suppor Suppor t of In ju ncti ve Issuance Issuances s


Page Page 21 of 26

All the foregoing arguments are repleaded hereunder. The urgency and me m eri t for f or the th e grant of the th e praye pr ayerr for f or a TR TRO and/ and/ or WP W PI under u nder Se Secti ons 3 and 4 of Rule 58 of the Rules of Court are succinctly depicted in the foregoing allegations and arguments.

It is reiterated that as parents and professionals, the RH Law Law in abdicating their parental right over their minor children and grandchildren hits petitioners as oppressive, unjust and confiscatory thus, unconstitutional. Petitioners are devout and practising Catholics whose religious beliefs find the mandatory provisions of the RH Law obnoxious and unconscionable. If the questioned law is implemented, petitioners will suffer untold prejudice and great damage made more evil by the fact that such stems from a patently void issuance. Petitioners are entitled to the relief demanded and the whole or part of such such reli ef pe p endi ng fi na nall determ determii na nati ti on of t his hi s case cons consii sts in r estra tr ai ni ng the act of Respondents in implementing or enforcing the questioned law before it takes effect on January 17, 2013. The i mpl eme mentation ntation by Respondents pondents of of t his hi s inv al id law w he hen n i t t akes kes effect on January 17, 2013 is in gross violation of the constitutional rights of petitioners respecting the subject of this action or proceeding, and will tendto r end nde er the jud gment i n thi t his s case i ne neff ffe ectua tu al . In view of the foregoing, there is therefore extreme urgency in this case because Petitioners will suffer grave injustice and great or irreparable damage or injury before the matter can be heard on notice if Respondents w i ll be al low ed to t o im ple pl eme ment nt and enforce enforce que ques sti one oned d l aw w hich is void. void . There is therefore a need to immediately preserve the status quo meantime before the matter can be heard on notice for which a temporary restraining order is hereby most respectfully prayed for in order to temporarily restrain Respondents from enforcing or implementing the null and void l aw .


Page Page 22 of 26

Prayer

W H ERE REFOR FORE E, pre pr emi ses consid conside ered, i t is most most r espectf pectfu u l l y pra pr ayed of thi s H onorable onorable Court Court :

A) To forthwith issue a temporary restraining order to preserve the status quo restraining the Respondents from implementing Republic Act No. 10354 entitled An Act Providing for a National Policy on Responsible Parenthood and Reproductive Health dated December 21, 2012, and, after due notice and hearing, issue the corresponding writ preliminary injunction pendi pe ndi ng tthe he fi nal de d etermi na nati ti on of thi th i s case;

B) Af ter due notic noti ce and heari heari ng, to render render jud gment,granting: gment,granti ng:

1)

a writ of certiorari declaring Republic Act No. 10354 null and void voi d ab ab initi ini ti o for bei bei ng c cons onsti ti tuti tu tiona onall ly infi inf i rm; rm ; and

2)

a writ of prohibition directing respondents to refrain and or cease ase and desi desi st fr f r om imp i mpll ementi ng Repu publ blii c A ct N o. 10 1035 354. 4.

Other re r emedie medi es just and equit able are are li kew kew i se pra pr ayed for. f or. Cagaya Ca gayan n de d e Oro Or o City Cit y f or M anil a, January 14, 20 2013 13,, P Phi hi l i pp ppii nes. nes.

GAM GA M BE & YAP LAW O FFI CE CES S Counsels for Petitioners Mandumol, Upper Macasandig Cagayan de Oro City Tel N o. (08822 (08822)) 72-15-75 72-15-75

EARL ANTH ON Y C. C. GAM BE Email A dd r ess: gambil gambi l ocd ocd o@gmail gmai l .com .com PTR No. N o. 3103 310396 966 6 (01/ (01/ 11 11// 13 13)) CDO


Page Page 23 of 26

I BP Li f eti me Member N o. 06 0630 307 7 ROLL N O. 3382 33825 5 M CLE COC N o. 3-00 3-0001 0106 069 9 (03/ (03/ 23 23// 09 09)) M obil obi l e No. N o. 09177 0917717 1762 6231 31

M ARLON ARLON I. YAP YAP Roll ol l N o. 514 51415 15 I BP O.R. N o. 85 8572 7246 46 (12/ (12/ 19 19// 20 2012 12)) CDO PTR No. N o. 231 23178 7843 43 A (12/ (12/ 19 19// 20 2012 12)) CDO CD O M CLE Exemp Exempti ti on No.III-00 No.II I-001 1942 (03 (03/ 16/ 11 11))

Republic of the Philippines) City of Cagayan de Oro. . .) S.S.

V ER I FI C A T I O N Wi th Certifi cation of N on-Forum n-Forum Shopping Shopping

We, all of the undersi undersi gned, gned, Filipinos, of legal age and residents of Cagayan de Oro City, under oath, depose and state: That w e ar ar e the Pe Peti ti one onerr s i n the t he a above-ca bove-capt ptii oned cas case; That we have caused the preparation and filing of the foregoing Petition for Certiorari and Prohibition with an application for a Temporary Restraining Order and or w ri t of Pre Prelili mina mi nary ry Injuncti Injunction; on;


Page Page 24 of 26

That w e have r ead the same same and the th e cont conte ents nt s the th er eof are true tr ue and cor cor r ect to the be bes st of our ow n persona personall know k now l edge and belie beli ef and bas based on aut authe henti nti c records; That w e he hereby reby ce cert i fy that we w e have not heretof heretofore ore comm comme enced nced any ac acti on or proc pr oce eedi ng i nvolv nv olv i ng the same i ssues i n the Court of Ap pea peall s or any any other other court, our t, tr i bunal or age gency; ncy; that to the be bes st of our know l edge no such acti on proc pr oce eedi ng i s pe pendi ndi ng in the afore for eme menti nti one oned d C Courts ourts or di ffe ff erent di vi si ons thereof, thereof, or or any any tri tr i bunal or age gency; ncy; and that shoul d we w e thereaft thereaft er lear lear n that that a si mi l ar acti on or proc pr oce eedi ng has be bee en fi led or i s pending pendi ng be befor fore e any of the afore for esai d Court s, tri bunal or age agency, ncy, w e he hereby reby unde und erta rt ake to infor in form m the th e afore for esaid Cour Co urts ts and such such othe otherr tribu tr ibuna nall or age genc ncy y of tha th at fact fact w i thi n fi ve (5) (5) days days therefrom. IN WI TNES TN ESS WH ER EREOF EOF,, w e have he hereunto reunto aff aff i xed xed our si gnature gnatur es, this thi s 14th 14 th d ay of January 2013 2013,, i n the City Ci ty of Caga Cagayan yan de Oro, Or o, Phil hi l i pp ppii nes. nes.

D R. N ESTOR B. LUM ICAO, M D

D R. ROD M . ALEN ALEN TON , M D

Dr i v er ’ s Li cense cense N o.N o.N17 17-74 -74-00 -006-4 6-494 94 I n hi s personal capacit capacity y and as A ttorney-i tt orney-i n-fact n-fact of SERVE LIFE LI FE CDO IN C.

Dr i v er ’ s Li cense cense N o. K03-81-0 K03-81-006 0679 792 2 I n hi s personal capacit capacity y and as A ttorney-i tt orney-i n-fact n-fact of ROSEVAL E FOUNDA TION IN C.

D R. LOV EN I A P. N ACES ACES, Phd.

ROSE ROSEM ARI E R. ALEN ALEN TON

SSS I D N o.09-064 o.09-06415 1510 10-0 -0

D r i v er’s er’ s Li cense cense N o. KO3-95 KO 3-95-03 -0309 0987 87

IM ELDA G. IBAR IBARRA RA

AN TH ON Y G. N AGAC

Dr i v er ’ s Li cense cense N o.KO2-95-0 o.KO2-95-060 608-2 8-22 2

Dr i v er ’ s Li cense cense N o. KO2-94-05 KO2-94-0559 5953 53

EARL AN TH ON Y C. GAM BE

M ARLON I . YAP

Dr i v er ’ s Li cense cense N o.KO1-79-0 o.KO1-79-007 0725 254 4

Tax I denti fi cati cati on N o.2 o.251 51-23 -239-9 9-987 87-00 -000 0

SUBSCR UBSCRII BED BED A N D SW ORN TO BEFORE BEFORE M E, thi s 14th 14th d ay of January 2013 20 13,, i n the th e City Ci ty of Ca Cagayan gayan d e Oro, Or o, Phil hi l i pp ppin ine es.

D oc. N o._________ o._________;; Page No.______ N o._________; ___; Book N o._____ o.________ ____; _; Seri es of 201 2013 3


Page Page 25 of 26

EXPLA XPLA N A TION / PROOF OF SERVICE VI CE

Pursuant to Section 11 of Rule 13 of the Rules of Court, we hereby certify that copies of the foregoing Petition for Certiorari and Prohibition with a prayer for a restraining order and a writ of preliminary injunction were furnished to each of the Respondents thru registered mail on January 14, 2013 as indicated below because personal service is impractical in view of the distance of their offices.

EA RL AN THON Y C. GAM BE

M A RLON I. YAP

CC:: CC OFFICE OF THE TH E PRE PRES SI D EN ENT T Republ ic of the t he Phili hi li ppi ne nes s M alacaña alacañang ng Palace alace, M anil a; Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013 TH E SENA TE Republ ic of the t he Phili hi li ppi ne nes s GSIS Complex, RoxasBlvd., Pasay City Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013 TH E H OUS OU SE OF REP REPRE RES SEN ENTA TA TIV TI V ES Republ ic of the t he Phili hi li ppi ne nes s Bata atas san H il l s, Quezon Quezon Ci City ty Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013 H ON. ON . PA PA QUITO QUI TO N. N . OCH OCH OA, OA , JR. Exec xecuti ut i ve Se Secretary, Of fi ce of of the P Pres resid id ent of t he P Phi hill i ppi ne nes s M alacaña alacañang ng Palace alace, M anil a; Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 2013 2013 H ON. ON . FLORE FLOREN N CIO B. B. ABAD Secretary, Department of Budget and Management (DBM) M alacaña alacañang ng Palace alace, M anil a; Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013 H ON. ON . EN EN RIQUE T. ONA Secretary, De D epartme partm ent of H eal th (DOH ) San Lazaro Compound, City of Manila;


Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013 H ON. ON . ARM ARMIN IN A . LUI STRO, TRO, FS FSC Secretary, Department of Education (DepEd) DepEd DepEd Comple Compl ex, M er al co A venue, venue, Pa Pasi g City; Cit y; Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 13, 13, 2013 2013 H ON. M A N UE UEL L A . ROXAS II Secretary, De D epartme partm ent of Interi I nteri or and Loc L oca al Governm Governme ent (D IL G) EDS DSA A cor. M apagmahal pagmahal St., Di l i man, Quezon Quezon City; Cit y; and Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013 TH E SOLI OL I CITOR GEN GEN ER ERA AL 139 A Amor mors solo Str eet, Le L ega gas spi Vi ll age ge,, M akati City Cit y Regi Re gistr stry y Re Rece ceii p t N o. _____ _______ ____ ___ _ d ated Janu January ary 14, 14, 2013 2013

Page Page 26 of 26

Revised Petition for Certiorari vs RH -Final

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