PLAINTIFFS TRIAL MEMORANDUM Plaintiff, through counsel, most respectfully alleges: STATEMENT OF FACTS In order that this honorable

court may be enlightened and guided in the judicious disposition of the above-entitled case, cited hereunder the material, relevant and pertinent facts of the case to wit: 1. Plaintiff is the proponent while defendant is the opponent of the RH Bill of the Philippines. 2. Plaintiff and defendant have different views of arguments concerning RH Bill. 3. Plaintiff alleged that rapid population growth among the poor can intensify poverty. 4. Plaintiff stated that there should be effective methods in controlling birth. 5. Plaintiff said that the use of contraception will lower the rate of abortions. 6. Plaintiff explained that the RH Bill is very much helpful in family planning. 7. According to the plaintiff, RH Bill is the ultimate solution to combat poverty and hunger at the household level. 8. Defendant mentioned that RH Bill is harmful to the society. 9. Defendant said that contraception is dangerous to the health of women. 10. Defendant also expressed that contraceptives can contribute negative results as to the health of women. 11. Defendant stated that increase of population is not the issue. Good governance and proper utilization of technology and natural resources is the main concern. STATEMENT OF ISSUES 1. Whether or not plaintiff established convincing reasons regarding the use of contraceptives. 2. Whether or not plaintiff has made effective solution in helping the poor. 3. Whether or not defendant raised valid reasons concerning negative effect of the RH Bill. 4. Whether or not defendant justified that RH Bill is harmful to the society. ARGUMENTS 1. Plaintiff stated some benefits that introduced by the RH Bill because this could be of great help to protect and strengthen the family. Pursuant to the declaration of State policies under Section 12 Article II of the 1987 Constitution, it is the duty of the State to protect the family as a basic autonomous social institution and equally protect the life of the mother and the life of the unborn from conception. 2. Defendant failed to explain the concrete negative effect of the RH Bill. 3. Defendant may be held liable when using statements against RH Bill without valid reasons and/or legal grounds. PRAYER Wherefore, it is respectfully prayed for this Honorable Court that judgment be rendered ordering the defendant to pay moral damages for the plaintiff. Plaintiff likewise prays for costs and for such other and further relief as this honorable court may deem just and equitable in the premises. Cebu, Philippines, March 6, 2013