clear policy guidelines on home births and the enactment of ordinances, the practice will continue, posing threats of penalty for women, especially those who are most marginalized. As pointed out during validation, however, there is a need to blange this with the priority goal of addressing maternal mortality. Aside from barriers posed by decentralization, the DOH is likewise constrained by legal barriers in the implementation of the RPRH law. Specifically, the Supreme Court’s issuance of TRO on Implanon and the impact of the SC ruling on Imbong vs. Ochoa. While the latter upheld the constitutionality of the RPRH law, it voided 8 key provisions including penalties for government officials refusing to implement the RPRH on the basis of ‘conscientious objection.’ It has likewise been used by many health service providers as requiring spousal consent for RH services like tubal ligation. While decentralization and autonomy of LGUs is enshrined in current laws, the views of the CEDAW committee in the Manila Inquiry is clear that it cannot be made an excuse to renege on the State’s obligation under CEDAW. Despite autonomy and decentralization, the Committee has made clear that “decentralization of power through devolution does not in any way negate or reduce the direct responsibility of the State party to fulfil its obligation to respect and ensure the rights of all women within its jurisdiction 13.” It added that safeguards and mechanisms must be in place to ensure that “decentralization or devolution does not lead to discrimination with regard to the enjoyment of rights by women in different regions. 14”From the foregoing, it is clear that as part of its obligation under CEDAW, including the obligation to eliminate barriers that women face in accessing health services, it is the State’s obligation to review and revoke discriminatory policies, legal and regulatory barriers to women’s enjoyment of RH rights. 2. DESPITE PASSAGE OF AND CURRENT NATIONAL IMPLEMENTATION OF THE RPRH LAW, CHALLENGES CONTINUE ON DE FACTO AVAILABILITY, ACCESSIBILITY, SUFFICIENCY, AND ADEQUACY OF RH SERVICES AND INFORMATION In terms of Availability, Accessibility, Sufficiency and Adequacy of RH Services and Information, the National Inquiry documented experiences which ranged from excess in terms of commodities, to inadequacy, insufficiency, and inaccessibility in the provisions of RH commodities and services for women who are vulnerable and most marginalized – 13 14 CEDAW/C/OP.8/PHL/1 Id 20