(reading: 25 minutes; post-graduate level)
The United Nations considers access to birth control to be a universal human right, but that right is increasingly denied even in democratic States. According to the World Health Organization (WHO), education and information on sexual and reproductive health, combined with access to contraception, have been proven to reduce teenage pregnancies, unsafe abortions, maternal morbidity and mortality, and the transmission of STDs.[i] Policies that effectively ban contraception choices violate international human rights law. Therefore, this paper examines a case study on the international legal findings by the United Nations Committee on the Elimination of Discrimination against Women that may shed light on the declining situation for women and adolescents of the United States of America and elsewhere. As women’s rights to sexual and reproductive healthcare are increasingly threatened, knowledge sharing is essential.
“HHS is aligning the program with President Trump’s pro-life and pro-family agenda.”
Emily Hilliard, a spokesperson for the United States Department of Health and Human Services
The impacts of the United States’ increasing interference on contraception can be foreseen through the case study of a situation in the Philippines from between 2004 – 2012. The rhetoric of the public policy planning is alarmingly similar to the current U.S. Administration’s. Under a multi-party democracy with an elected president and legislature, women and girls in the Philippines were effectively denied access to contraception and comprehensive information on sexual and reproductive health rights (SRHR), including family planning.
Case study: inquiry concerning the Philippines
In 2008 the Committee on the Elimination of Discrimination against Women received a joint submission from NGOs in the Philippines related to legislative acts imposed by concurrent mayors of Manila. A decentralization of health services, family planning and population development in the Philippines allowed the Manila City Council to enact legislation by ordinance, while the mayor had the authority of executive orders.
“Executive Order No. 003 recalled the sanctity of life including the protection of the life of the mother and the unborn, as enshrined in the Constitution, and declared that the City of Manila would take an ‘affirmative stand on pro-life issues’ (…).” “The Order also provided that the City would ‘promote responsible parenthood and uphold natural family planning not just as a method but as a way of self-awareness in promoting the culture of life while discouraging the use of artificial methods of contraception like condoms, pills, intrauterine devices, surgical sterilization, and other’.”[ii]
While Executive order No. 003 did not expressly prohibit the use of contraceptives, the implementation of the policies in practice severely limited access, which effectually resulted in their banning in Manila. The situation was worsened by the subsequent mayor, who continued its implementation and issued Executive Order No. 030, which imposed a funding ban on modern contraception.
Both mayors who imposed these executive orders were Catholic.
The CEDAW Committee considered the complaint information received “to be reliable and indicative of grave or systemic violations”[iii] according to international standards. As such, they conducted a confidential inquiry through the assistance of relevant NGOs to investigate the availability of contraceptives in Manila. They found evidence women and girls were provided with information on ‘natural family planning’ but were given misinformation about modern methods of contraception even though listed as Essential Medicines by the World Health Organization.[iv]
By excluding access to the full range of sexual and reproductive health services and commodities between 2007-11, women in Manila experienced damaging impacts on their health and lives. In particular, the executive orders “had detrimental consequences for economically disadvantaged women and drove them further into poverty by depriving them of an opportunity to control the number and spacing of their children.”[v] The multiple pregnancies adversely affected women’s mental and physical health, increased their exposure to STDs including HIV/AIDS, and “contributed to tension with their husbands or partners and fostered domestic violence.”[vi]
Executive Order Nos. 003 and 030 negatively affected women as
“such implementation over many years had a severe impact on their health and on their access to adequate health care services. The Committee observes that the lives and health of many women were put at risk, given that they were compelled to have more children than they wanted or than their health permitted them to have. The Committee particularly takes note of the potentially life-threatening consequences of unplanned and/or unwanted pregnancies as a direct consequence of the denial of access to the full range of contraceptive methods, as well as of the strict criminalization of abortion without any exemptions provided for in the State party’s legislation. Complications resulting from unsafe and illegal abortions are a prominent cause of maternal death in Manila, as acknowledged by the State party. It is therefore evident for the Committee that the failure of the State party to provide the full range of sexual and reproductive health services, commodities and information resulted in unplanned pregnancies, unsafe abortions and unnecessary and preventable maternal deaths.”[vii]
The Committee also found that “adolescent girls were exposed to an increased risk of unwanted pregnancies and pregnancy-related injuries or death following unprotected or coerced sex, to which they are particularly vulnerable.”[viii]
In the Manila case, the CEDAW Committee clarified that
“distinctive health features that differ for women in comparison to men include biological factors such as women’s reproductive functions. Given that such factors have a bearing on women’s reproductive health needs, the Committee considers that substantive equality requires that States parties attend to the risk factors that predominantly affect women. Given that only women can become pregnant, lack of access to contraceptive is therefore bound to affect their health disproportionately. (…) Women in Manila primarily bore the consequences of and were disproportionately disadvantaged by the inability to gain access to and use the full range of reproductive health services, including modern methods of contraception.”[ix]
The CEDAW Committee found the Republic of the Philippines in violation of the CEDAW Convention, Articles 2 (d), 2 (f) and Article 12.
The prohibition of discrimination and the right to health
According to Article 2 of CEDAW
States Parties condemn discrimination against women in all its forms, agree to pursue by all appropriate means and without delay a policy of eliminating discrimination against women and, to this end, undertake:
(a) To embody the principle of the equality of men and women in their national constitutions or other appropriate legislation if not yet incorporated therein and to ensure, through law and other appropriate means, the practical realization of this principle;
(…)
(d) To refrain from engaging in any act or practice of discrimination against women and to ensure that public authorities and institutions shall act in conformity with this obligation;
(…)
(f) To take all appropriate measures, including legislation, to modify or abolish existing laws, regulations, customs and practices which constitute discrimination against women
The Convention on the Elimination of Discrimination against Women (CEDAW) provides for family planning services, in Article 12, para. 1.
1. States Parties shall take all appropriate measures to eliminate discrimination against women in the field of health care in order to ensure, on a basis of equality of men and women, access to health care services, including those related to family planning.
The Committee on the Elimination of Discrimination Against Women distributed General Recommendation No. 24: Article 12 of the Convention (women and health) in 1999. It clarified the obligations of the State, including
13. The duty of States parties to ensure, on a basis of equality of men and women, access to health-care services, information and education implies an obligation to respect, protect and fulfil women’s rights to health care. States parties have the responsibility to ensure that legislation and executive action and policy comply with these three obligations. They must also put in place a system that ensures effective judicial action. Failure to do so will constitute a violation of article 12.[x]
Furthermore,
17. The duty to fulfil rights places an obligation on States parties to take appropriate legislative, judicial, administrative, budgetary, economic and other measures to the maximum extent of their available resources to ensure that women realize their rights to health care. Studies such as those that emphasize the high maternal mortality and morbidity rates worldwide and the large numbers of couples who would like to limit their family size but lack access to or do not use any form of contraception provide an important indication for States parties of possible breaches of their duties to ensure women’s access to health care. [xi]
Whiles those obligations cited under the Manila investigation by the CEDAW Committee are owed under the Convention, there are other international human rights and domestic legal obligations that may also apply.
Similar rights and fundamental freedoms, such as the prohibition of discrimination, frequently fall under multiple treaties because human rights are both interdependent and interrelated. Many obligations will be owed by several UN Member States, depending on the treaties they have each ratified; their domestic law should reflect those human rights accordingly.
Health rights and reproductive freedoms
Access to contraception is anchored in international human rights lawunder the right to health, which is found in Article 12 of the International Covenant on Social, Economic and Cultural Rights (ICESCR).
ICESCR – Article 12
1. The States Parties to the present Covenant recognize the right of everyone to the enjoyment of the highest attainable standard of physical and mental health.
2. The steps to be taken by the States Parties to the present Covenant to achieve the full realization of this right shall include those necessary for:
(a) The provision for the reduction of the stillbirth-rate and of infant mortality and for the healthy development of the child;
(b) The improvement of all aspects of environmental and industrial hygiene;
(c) The prevention, treatment and control of epidemic, endemic, occupational and other diseases;
(d) The creation of conditions which would assure to all medical service and medical attention in the event of sickness.
The Economic and Social Council (ECOSOC) – Committee on Economic, Social and Cultural Rights (CESR) is tasked with the interpretation of the International Covenant on Economic, Social and Cultural Rights (ICESCR). The Committee provides clarity on the normative content of Article 12 in its General Comment No. 14 as follows.
(8.) The right to health is not to be understood as a right to be healthy. The right to health contains both freedoms and entitlements. The freedoms include the right to control one’s health and body, including sexual and reproductive freedom, and the right to be free from interference, such as the right to be free from torture, non-consensual medical treatment and experimentation. By contrast, the entitlements include the right to a system of health protection which provides equality of opportunity for people to enjoy the highest attainable level of health.[xii]
Furthermore, the State is bound to the principle of non-discrimination, including discrimination according to sex and gender. Specifically,
“States are under the obligation to respect the right to health by, inter alia, (…) abstaining from imposing discriminatory practices relating to women’s health status and needs. (…) In addition, States should refrain from limiting access to contraceptives and other means of maintaining sexual and reproductive health, from censoring, withholding or intentionally misrepresenting health-related information, including sexual education and information, as well as from preventing people’s participation in health-related matters.”[xiii]
The Committee on Economic and Social Rights interprets Article 12.2 (a), The right to maternal, child and reproductive health, as follows.
14. “The provision for the reduction of the stillbirth rate and of infant mortality and for the healthy development of the child” (art. 12.2 (a))10 may be understood as requiring measures to improve child and maternal health, sexual and reproductive health services, including access to family planning, pre- and post-natal care,11 emergency obstetric services and access to information, as well as to resources necessary to act on that information.”
The United Nations Office of the High Commissioner (OHCHR) also recognized that “sexual and reproductive health is an integral part of the right to health”[xiv] when they published General Comment No. 22 on the right to sexual and reproductive health (article 12 of the International Covenant on Economic, Social and Cultural Rights) in 2016.
Under the normative content of the right to sexual and reproductive health, the OHCHR stated that “Essential medicines should also be available, including a wide range of contraceptive methods, such as condoms and emergency contraception, medicines for abortion and for post-abortion care, and medicines, including generic medicines, for the prevention and treatment of sexually transmitted infections and HIV.”[xv]
Furthermore, “Unavailability of goods and services due to ideologically based policies or practices, such as the refusal to provide services based on conscience, must not be a barrier to accessing services. An adequate number of health-care providers willing and able to provide such services should be available at all times in both public and private facilities and within reasonable geographical reach.”[xvi] This is applicable not only to contraception, but also to abortion and post-abortion care. Policy making based on ideology alone runs counter to human rights.
Freedom of religion serves atheists too
Often referred to as the ‘separation of church and State’ in domestic law, international law prohibits discrimination on the basis of religion or beliefs – this includes the protection of those who choose no religion. This provision is found in the International Covenant on Civil and Political Rights (ICCPR) (1966).
ICCPR – Article 18
1. Everyone shall have the right to freedom of thought, conscience and religion. This right shall include freedom to have or to adopt a religion or belief of his choice, and freedom, either individually or in community with others and in public or private, to manifest his religion or belief in worship, observance, practice and teaching.
2. No one shall be subject to coercion which would impair his freedom to have or to adopt a religion or belief of his choice.
3. Freedom to manifest one’s religion or beliefs may be subject only to such limitations as are prescribed by law and are necessary to protect public safety, order, health, or morals or the fundamental rights and freedoms of others.
4. The States Parties to the present Covenant undertake to have respect for the liberty of parents and, when applicable, legal guardians to ensure the religious and moral education of their children in conformity with their own convictions.
Article 18 protects theistic, non-theistic and atheistic beliefs, as well as the right not to profess any religion or belief. The terms belief and religion are to be broadly construed.
General Comment No. 22 by the United Nations Human Rights Committee (1993)
Freedom of religion also entails the right to have no religion at all. In 1993 the United Nations Human Rights Committee (UNHRC) adopted General Comment No. 22 to clarify the scope of Article 18 of the ICCPR.
2. Article 18 protects theistic, non-theistic and atheistic beliefs, as well as the right not to profess any religion or belief. The terms belief and religion are to be broadly construed.
(…)
5. The Committee observes that the freedom to “have or to adopt” a religion or belief necessarily entails the freedom to choose a religion or belief, including, inter alia, the right to replace one’s current religion or belief with another or to adopt atheistic views, as well as the right to retain one’s religion or belief. Article 18 (2) bars coercions that would impair the right to have or adopt a religion or belief, including the use of threat of physical force or penal sanctions to compel believers or non-believers to adhere to their religious beliefs and congregations, to recant their religion or belief or to convert. Policies or practices having the same intention or effect, such as for example those restricting access to education, medical care, employment or the rights guaranteed by article 25 and other provisions of the Covenant are similarly inconsistent with article 18 (2). The same protection is enjoyed by holders of all beliefs of a non-religious nature.
‘Natural family planning’, which was promulgated in the Executive Orders 003 and 030 in Manila, is central to Catholic teaching. However, under Article II of the 1987 Constitution of the Republic of the Philippines, Declaration of Principles and State Policies Principles, “The separation of Church and State shall be inviolable.”[xvii] The CEDAW Committee found that despite the inviolability of Church and State “the Church has considerable influence on policy making. Religion has been relied upon as the basis for sexual and reproductive health policies, including at the level of local government units”.[xviii]
Likewise, the First Amendment of the Constitution of the United States of America states that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof”.[xix] The United States Courts (.gov) website, reads “Today, what constitutes an ‘establishment of religion’ is often governed under the three-part test set forth by the U.S. Supreme Court in Lemon v. Kurtzman, 403 U.S. 602 (1971). Under the ‘Lemon’ test, government can assist religion only if (1) the primary purpose of the assistance is secular, (2) the assistance must neither promote nor inhibit religion, and (3) there is no excessive entanglement between church and state.”[xx]
In 2009 the Republic of the Philippines adopted an Act providing for a comprehensive women’s human rights instrument – the Magna Carta of Women (Republic Act No. 9710). The Act incorporated elements of the Universal Declaration of Human Rights such as the principle of non-discrimination, and much of the CEDAW Convention, into the Philippine national framework.
Section 3 of the Magna Carta of Women affirms a general principle of international law, which is that because human rights are interdependent and interrelated “the fulfillment of one right often depends, wholly or in part, upon the fulfilment of others”[xxi]. Unfortunately, the Philippine government failed to fully implement the Act, specifically on family planning provisions from Section 17 – Women’s Right to Health, and to monitor for compliance. Essentially, human rights were violated by integrating religious doctrine into public policy.
Freedom of expression and the right to receive information
States have an obligation to provide comprehensive information on healthcare, including contraception methods, their effectiveness and side effects. Campaigns of misinformation and disinformation by the State may be a human rights violation.
The World Health Organization states that “people must have guaranteed access to sexuality education, including information about contraceptives, that enables them to decide freely and responsibly the number and spacing of their children, as well as access to specific educational information to help ensure the health and well-being of families”.
The International Declaration of Civil and Political Rights (ICCPR), Article 19, provides for the fundamental freedom of expression. The clause on the right to receive information is found within Article 19, para. 2.
2. Everyone shall have the right to freedom of expression; this right shall include freedom to seek, receive and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing or in print, in the form of art, or through any other media of his choice.
Freedom of expression and the right to seek and receive information, according to Article 19 of the ICCPR, combined with the right to health, was expressed in the Committee on Economic, Social and Cultural Rights’ (CESR) General Comment No. 14: The right to the highest attainable standard of health.
8. (…) States should refrain from limiting access to contraceptives and other means of maintaining sexual and reproductive health, from censoring, withholding or intentionally misrepresenting health-related information, including sexual education and information, as well as from preventing people’s participation in health-related matters.”[xxii]
The Philippine Magna Carta of Women, which took effect on September 15, 2009, provides the right for women and girls to receive information related to their sexual and reproductive health.
“All people have the right to participate in and access information relating to the decision-making processes that affect their lives and well-being.”[xxiii]
That statement is consistent with the World Health Organization and the United Nations’ own statements and recommendations.
State responsibility and the devolution of powers in domestic law
As the primary subjects of international law, the nation State bears responsibility for all acts and omissions that violate international agreements – not the sub-national levels of government whether provincial, territorial, regional or local. As clarified in the International Law Commission’s Responsibility of States for Internationally Wrongful Acts (2001), General Commentary, “The State is treated as a unity, consistent with its recognition as a single legal person in international law.”[xxiv] Therefore, the Philippines bears responsibility for all acts and omissions by its sub-national government entities, including the City of Manila. So too does the United States of America, for example, over any of its sub-national States. This principle runs throughout international law.
See CEDAW’s General Comment No. 28, paragraph 39, on the devolution of powers.
39. “…The decentralization of power, through devolution and delegation of Government powers in both unitary and federal States, does not in any way negate or reduce the direct responsibility of the State party’s national or federal Government to fulfil its obligations to all women within its jurisdiction. In all circumstances, the State party that ratified or acceded to the Convention remains responsible for ensuring full implementation throughout the territories under its jurisdiction. In any process of devolution, States parties have to make sure that the devolved authorities have the necessary financial, human and other resources to effectively and fully implement the obligations of the State party under the Convention. The Governments of States parties must retain powers to require such full compliance with the Convention and must establish permanent coordination and monitoring mechanisms to ensure that the Convention is respected and applied to all women within their jurisdiction without discrimination. Furthermore, there must be safeguards to ensure that decentralization or devolution does not lead to discrimination with regard to the enjoyment of rights by women in different regions.”[xxv]
Findings of human rights violations are attributed to the State under whose jurisdiction the violations occurred. This was affirmed in the Magna Carta of Women under Section 3.
States and other duty-bearers are answerable for the observance of human rights. They must comply with the legal norms and standards enshrined in international human rights instruments in accordance with the Philippine Constitution. Where they fail to do so, aggrieved rights-holders are entitled to institute proceedings for appropriate redress before a competent court or other adjudicator in accordance with the rules and procedures provided by law.[xxvi]
The tacit acceptance or official endorsement of violations of international law, as attributable to the State, was confirmed by the International Court of Justice in the case of United States Diplomatic and Consular Staff in Tehran, United States v Iran (1979).[xxvii]
A comparative analysis of the international legal framework between the Philippines and the United States
Consent to jurisdiction is a primary consideration in international law. Each nation State will have differing legal obligations which are dependent on their consent through the ratification of treaties, conventions and other legal instruments. This is notwithstanding customary international law, general principles of international law, and jus cogens, which are non-derogable norms.
The Philippines ratified the Convention on the Elimination of Discrimination against Women (CEDAW) on August 5, 1981, and its corresponding optional protocol on November 12, 2003. In accordance with Articles 8 and 9 of the CEDAW Optional Protocol , the Philippines accepted the Inquiry procedure on November 12, 2003. Previous to that, the Philippines ratified the International Covenant on Civil and Political Rights on October 23, 1986, and the International Covenant on Economic, Social and Cultural Rights on June 7, 1974. The Philippines has ratified eight out of nine core international human rights treaties[xxviii] and four out of a possible five optional protocols; the optional protocols provide the United Nations treaty bodies jurisdiction over complaints of alleged human rights abuses in violation of their corresponding treaties.
The United States of America signed the CEDAW on July 17, 1980, but failed to ratify the Convention and its optional protocol, so it is not a member party. Similarly, the U.S.A signed the International Convention on Economic, Social and Cultural Rights on October 5, 1977, but never ratified that Covenant either. The United States has ratified only three of the nine core human rights treaties and zero out of five optional protocols. The U.S.A. did however ratify the International Covenant on Civil and Political Rights (ICCPR) on June 8, 1992,[xxix] but unfortunately did not ratify either of its two optional protocols, which would have given the United Nations Human Rights Committee jurisdiction to hear complaints from individuals on civil and political rights abuses. Effectively, this means that protection from human rights abuses in the United States is reliant mostly on domestic remedies. However, customary international law, general principles of international law and jus cogens may be applicable under specific circumstances.
Conclusion
In April 2026 United States’ President Donald Trump released new guidance intended to overhaul family planning services, prioritizing childbirth over contraception.[xxx] Then in July of 2026 the Trump Administration gutted funding for 53 programs intended and proven to reduce teen pregnancies, because they were allegedly ‘normalizing sexual activities for minors’[xxxi]. These acts and omissions are likely to have dire consequences on the population of women and girls in the United States, undermining their rights to non-discrimination, the right to privacy and bodily autonomy, the right to health, the right to receive information, the right to education and the right to work. These human rights abuses will generally deepen gender inequality unless addressed.
The global rolling back of women’s rights continues. And while nation States may bear the legal responsibility, it is women, girls and gender diverse persons that bear the impact.
– August 2026
Additional resources:
See the World Health Organization’s Model List of Essential Medicines – 24th List (2025); 22. Medicines for Reproductive health and Perinatal Care; pages 54 – 55 includes (22.1) Contraceptives and (22.4) Medicines for medical abortion: mifepristone – misoprostol.
https://www.who.int/publications/i/item/B09474
See the World Health Organization’s Fact sheet on Emergency Contraception; Nov. 9, 2021; https://www.who.int/news-room/fact-sheets/detail/emergency-contraception and on Abortion; Dec. 8, 2025; https://www.who.int/news-room/fact-sheets/detail/abortion
[i] Family planning/contraception methods; published July 3, 2025; World Health Organization; https://www.who.int/news-room/fact-sheets/detail/family-planning-contraception (accessed Aug. 16, 2026)
[ii] Para. 2, Summary of the inquiry concerning the Philippines under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women; Committee on the Elimination of Discrimination against Women; April 22, 2015; CEDAW/C/OP.8/PHL/1.
[iii] Ibid, para. 3.
[iv] Ibid; Para. 8.
[v] Ibid; para. 13.
[vi] Ibid; para. 13.
[vii] Ibid; para. 33;
[viii] Ibid, para. 34.
[ix] Para. 32; General Comment No. 14 – Substantive issues arising in the implementation of the International Covenant on Social, Economic and Cultural Rights; 2000; United Nations Economic and Social Council, Committee on Economic, Social and Cultural Rights, E/C.12/2000/4.
[x] Para. 13; General recommendation No. 24: Article 12 of the Convention (women and health); 1999; Committee on the Elimination of Discrimination Against Women.
[xi] Ibid, para. 17. Summary of the inquiry concerning the Philippines under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women; Committee on the Elimination of Discrimination against Women; April 22, 2015; CEDAW/C/OP.8/PHL/1.
[xii] Para. 8, General Comment No. 14 – Substantive issues arising in the implementation of the International Covenant on Social, Economic and Cultural Rights; 2000; United Nations Economic and Social Council, Committee on Economic, Social and Cultural Rights, E/C.12/2000/4.
[xiii] Ibid. Para. 34.
[xiv] Para. 1; General comment No. 22 (2016) on the right to sexual and reproductive health (article 12 of the International Covenant on Economic, Social and Cultural Rights); 2016; United Nations Office of the High Commissioner; E/C.12/GC/22.
[xv] Ibid, Para. 13; footnote 15 (Essential medicines are defined by WHO as “those that satisfy the priority health care needs of the population” and that “are intended to be available within the context of functioning health systems at all times in adequate amounts, in the appropriate dosage forms, with assured quality, and at a price the individual and community can afford”. See Committee on Economic, Social and Cultural Rights general comment No. 14; and WHO, Model List of Essential Medicines, 19th ed. (2015).)
[xvi] Ibid, Para. 14; footnote 16 (International Planned Parenthood Federation – European Network v. Italy, complaint No. 87/2012 (2014), resolution adopted by the Committee of Ministers of the Council of Europe on 30 April 2014.)
[xvii] Constitution of the Republic of the Philippines; February 1987; https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/3/353
[xviii] Findings of fact; para. 7; Summary of the inquiry concerning the Philippines under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women; Committee on the Elimination of Discrimination against Women; April 22, 2015; CEDAW/C/OP.8/PHL/1.
[xix] Constitution of the United States; https://constitution.congress.gov/constitution/amendment-1/
[xx] First Amendment and Religion; United States Courts website; https://www.uscourts.gov/about-federal-courts/educational-resources/about-educational-outreach/activity-resources/first-amendment-and-religion (Accessed July 29, 2026)
[xxi] An act providing for the Magna Carta of Women; Republic Act No. 9710, Aug. 14, 2009. Section 3, paras. 2-3.
[xxii] Para. 8, General Comment No. 14 – Substantive issues arising in the implementation of the International Covenant on Social, Economic and Cultural Rights; 2000; United Nations Economic and Social Council, Committee on Economic, Social and Cultural Rights, E/C.12/2000/4.
[xxiii] An act providing for the Magna Carta of Women; Republic Act No. 9710, Aug. 14, 2009. Section 3, paras.
[xxiv] General Commentary – Chapter I – General Principles – [82] (6); ILC (2001) Responsibility of States for Internationally Wrongful Acts. International Court of Justice https://www.icj-cij.org/node/202882
[xxv] Para. 23 (39) CEDAW/C/OP.8/PHL/1
[xxvi] An act providing for the Magna Carta of Women; Republic Act No. 9710, Aug. 14, 2009. Section 3, para. 6.
[xxvii] Case concerning United States diplomatic and consular staff in Teheran (United States of America v. Iran); International Court of Justice; 29 November 1979. https://www.icj-cij.org/case/64
[xxviii] UN Treaty Body Database; Ratification Status for the Philippines; https://tbinternet.ohchr.org/_layouts/15/TreatyBodyExternal/treaty.aspx (Accessed August 4, 2026)
[xxix] UN Treaty Body Database; Ratification Status for the United States (accessed August 5, 2026)
https://tbinternet.ohchr.org/_layouts/15/TreatyBodyExternal/treaty.aspx
[xxx] Mary Zeigler; Trump Is Going After Birth Control. Here’s Why. April 25, 2026; Politico. https://www.politico.com/news/magazine/2026/04/25/birth-control-maha-abortion-trump-00889738
[xxxi] Trump administration cancels grants aimed at reducing teen pregnancies; NPR July 7, 2026; Selena Simmons-Duffin on Morning Edition. https://www.npr.org/2026/07/07/nx-s1-5875464/trump-administration-cancels-grants-aimed-at-reducing-teen-pregnancies
