Alliance for the Family Foundation, Inc. (ALFI) v. Garin
### Facts
– **Context**: The case stems from the Supreme Court’s decision in “Imbong v. Ochoa,” which partially upheld Republic Act No. 10354 (RH Law) but declared certain provisions unconstitutional, mainly focusing on the rights and definitions concerning reproductive health and abortifacients.
– **Initial Actions**:
– **May 28, 2014**: Petitioners (ALFI and other individuals) inquired from the Food and Drug Administration (FDA) about the agency’s compliance with the Supreme Court’s decision on the RH Law.
– **September 2014**: FDA issued a notice inviting Marketing Authorization Holders (MAH) to apply for re-evaluation/re-certification of 50 contraceptive drugs.
– **October 8, 2014**: ALFI submitted a preliminary opposition to all applications.
– **November 24, 2014**: ALFI filed a main opposition to 77 contraceptive drugs.
– **November 27, 2014**: FDA issued certificates of product registration for “Implanon” and “Implanon NXT”.
– **Subsequent Actions**:
– **March 19, 2015**: ALFI reiterated its opposition and requested updates and consultations, which went unanswered.
– **June 17, 2015**: The Supreme Court issued a Temporary Restraining Order (TRO) to stop the FDA and Department of Health (DOH) from granting approvals for reproductive products and distributing certain contraceptives, including “Implanon” and “Implanon NXT”.
### Procedural Posture
– **Petition for Certiorari (G.R. No. 217872)**: Filed by ALFI, arguing that the FDA committed grave abuse of discretion, violated due process, and did not follow Court’s guidelines from Imbong. They sought judicial intervention to enforce procedural reforms and constitutional protections.
– **Petition for Contempt (G.R. No. 221866)**: Filed by the same petitioners, alleging that the FDA violated the TRO by continuing to certify and distribute contraceptive products.
### Issues
1. **Locus Standi**: Whether the petitioners have the standing to file the petitions.
2. **Proper Remedy**: Whether certiorari is the appropriate legal remedy for challenging the FDA’s regulatory acts.
3. **Due Process Violations**: Whether the FDA and DOH violated procedural and substantive due process in certifying contraceptive products.
4. **Contempt of Court**: Whether the FDA and DOH acted in contempt by continuing their operations despite the TRO.
### Court’s Decision
– **Locus Standi**: The Court ruled that petitioners have standing given the transcendental importance of the issue, which involves the constitutional right to life of the unborn and potential misuse of public funds for alleged abortifacients.
– **Certiorari as Proper Remedy**: Court declared certiorari as appropriate to review FDA’s acts due to the constitutional implications and potential grave abuse of discretion.
– **Due Process Violations**:
– The FDA issued product certifications without conducting public hearings and without addressing petitioners’ oppositions.
– The Court found a lack of compliance with basic procedural due process and struck down the FDA’s certifications as void.
– The Court directed the FDA to adhere to detailed procedural guidelines ensuring due process protections in certifying contraceptives.
– **Motion to Lift TRO**: Denied to ensure that the FDA complies with procedural requirements.
– **Contempt of Court**: Denied due to lack of concrete proof of contumacious acts committed after the TRO was issued.
### Doctrine
1. **Due Process in Administrative Proceedings**: Administrative bodies must observe the basic tenets of due process, including notice, public hearings, and substantial evidence, even in regulatory functions (Ang Tibay Doctrine).
2. **Judicial Review over Administrative Actions**: Certiorari lies to review administrative actions when there is a grave abuse of discretion with constitutional implications.
3. **Protecting Constitutional Rights**: The Court emphasized that procedural rules and actions by administrative bodies must not infringe constitutional rights, particularly regarding the right to life and due process.
### Class Notes
– **Key Legal Concepts**:
– **Locus Standi**: Standing to sue based on public interest and constitutional violations.
– **Certiorari**: Appropriate for challenging grave abuse of discretion by administrative bodies.
– **Due Process**: Both substantive due process (validity of laws) and procedural due process (fair play, public hearings) are paramount.
– **Hierarchy of Courts**: Cases involving constitutional questions and public interest can be directly brought to the Supreme Court.
– **Expanded Judicial Review**: Courts can intervene in administrative actions affecting constitutional rights.
– **Statutory and Constitutional Provisions**:
– **Section 5(5), Article VIII, 1987 Constitution**: Supreme Court’s power to promulgate rules concerning the protection and enforcement of constitutional rights.
– **Republic Act No. 10354 (RH Law)**: Governs reproductive health rights and procedures.
– **Republic Act No. 3720**: Mandates FDA to ensure safety and efficacy of drugs.
### Historical Background
– The controversy arises amidst longstanding tensions in the Philippines over reproductive health rights and religious/moral opposition to contraceptives. The Supreme Court’s prior ruling in Imbong clarified many constitutional boundaries but left implementation challenges that surfaced in this case. This case represents ongoing judicial oversight to balance public health initiatives and constitutional safeguards.
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