Republic of the Philippines

BATANGAS STATE UNIVERSITY

The National Engineering University
Alangilan Campus
Golden Country Homes, Alangilan, Batangas City, Batangas, Philippines 4200
Tel Nos.: (+63 43) 425-0139 loc. 2121 / 2221
E-mail Address: [email protected] | Website Address: http://www.batstate-u.edu.ph

COLLEGE OF ENGINEERING
DEPARTMENT OF ELECTRONICS ENGINEERING

CANTOS, NICOLE COURTNEY M. 22-05689

CASTILLO, ERIC PIEL L. 22-04423
CASTILLO, MIKAELA M. 22-05611
CELIS, KARL JEUSH C. 22-09367
CERILLO, KEN L. 22-04653
ESGUERRA, JERICO L. 22-03207
ESQUILONA, WENNIE MAE M. 22-04575
FIEGALAN, CHERYL M. 22-02351
GARCIA, JULIA KRISTIANNA M. 22-02793
GEPIALA, JESSA M. 22-05724
ECE 1104

GEd 106: PURPOSIVE COMMUNICATION

ETHICAL AND JUDICIAL PERSPECTIVES: A STUDY OF LEGALIZING

EUTHANASIA IN THE PHILIPPINES

NOVEMBER 2022
I. Introduction

If you had a choice to end your current suffering, would you consider

euthanasia? According to Math and Chaturvedi (2012), euthanasia is a term that

dates back to ancient Greece and denotes a good death. It is the practice of

speeding up a patient's death to end their pain and suffering [16]. It has several

different forms, including active euthanasia, which introduce something to cause

death. Another is passive euthanasia, which is refusing treatment or supportive

measures. Then physician-assisted euthanasia, where a doctor prescribes a

medication, and the patient (voluntary) or a third party (involuntary) administers

the medication to cause death [16]. According to ProCon (2022), Samuel

Williams was the one to first proposed and publically advocate the usage of

anesthetics and morphine to deliberately end a patient's life in public in 1870 [2].

In 1996, a terminally ill Australian man became the first person in the world to

use legal euthanasia to end his life.

As of 2010, a few nations, some U.S. states including Belgium, the

Netherlands, and Switzerland, as well as Albania, allowed for the legalization of

physician-assisted suicide (PAS) or euthanasia. There are conflicting legal

precedents and laws in other nations, such as Japan and Columbia. Direct

euthanasia is prohibited, and physician-assisted suicide has been authorized in

Germany since the 18th century. Despite Japan's unequivocal prohibition on

euthanasia, a significant court ruling in 1962 laid out six criteria that a physician

must meet to legally perform the service for a patient. Columbia's highest court

approved euthanasia in 1997, although the Congress of Columbia has never

Page 1 of 53
confirmed the ruling. In the first decade of the twenty-first century, euthanasia

was legalized in Belgium and the Netherlands. In 2008, euthanasia and

doctor-assisted suicide were legalized in Luxembourg [7].

The legalization of euthanasia in the Philippines is opposed by religious

communities, despite the fact that it benefits patients who choose it to end their

agonizing torment from incurable and terminal diseases. Performing euthanasia is

illegal in the Philippines due to the religious communities' domination, which

prevents the ratification of the Euthanasia bill. Philippine Senate in the year 1997

considered passing a bill of legalization of passive euthanasia. The legalization of

passive euthanasia was once void due to the opposition of the Catholic Church,

from the religious perspective, that life is a gift from God and should not be

prematurely shortened.

The stance of the Church that euthanasia is still morally and ethically

wrong is one of the significant reasons why it is condemned. Knowing that the

catholic religion dominated the Philippines, most Filipinos value Christian

doctrine as the basis for their beliefs. The most recent version of the Catholic

Catechism of the Church, published in 2003, says that "all forms of suicide and

euthanasia remain strictly prohibited... Voluntary cooperation in suicide is

contrary to the moral law... And the sick persons should be helped to lead their

lives possibly as normal" [37]. In line with this, Pope John Paul II, in his written

document, wrote to reiterate the view of the Roman Catholic Church on the value

of life and warned against violating the sanctity of life. The pope stated,

"Euthanasia must not be called [a] false mercy, and indeed a disturbing perversion

Page 2 of 53
of mercy." It reaffirms that man must never deliberately kill or assist in killing

another human, as doing so disobeys one of the Ten Commandments and is

contrary to natural moral order [1]. Following a 2007 British Social Attitudes

study, 80% of the population stated that they wanted the law modified to allow

terminally ill patients the right to die with the assistance of a doctor. Patients with

non-terminal illnesses should have the option of euthanasia, according to 45% of

the respondents. The "majority" of people were against family members partaking

in a patient's passing (British Broadcasting Corporation, n.d.) [27]. In line with

this, another research stated that euthanasia is a more widely accepted method of

ending a life in the Netherlands. In 1988, 88% of the population supported such a

method of life deprivation, compared to 6% in 1975, when the population was 52.

The fact that 74% of Roman Catholics accept euthanasia is particularly intriguing

when people realize that the Catholic Church fiercely opposes it. According to

proponents of this type of deprivation of life, the main factor in this procedure

should be self-determination because respect for life involves avoiding an

inhumane end [9]. Additionally, legal and medical theories assert that while

patients do not fear assisted suicide, their greatest worry is that their request will

be denied.

Legalizing euthanasia has been a topic debated around the world for years.

Few countries considered implementing its practice, but it remains illegal to most,

such as the Philippines. Based on the Bulletin of the World Health Organization in

2001, the Netherlands was the first country to legalize euthanasia (Jakhar et al.,

2021) [15]. In the said country, euthanasia is administered by strictly following

Page 3 of 53
 statutory rules and procedures and obtaining consent. However, under the

Hippocratic Oath of physicians, traditional medical ethical codes have never

sanctioned euthanasia. Research businesses will no longer see the need to

investigate improved treatment options. Euthanasia, being deemed unethical, is

arguably the most significant drawback—with most religions viewing suicide or

killing as morally unacceptable, regardless of the situation.

Moreover, in the current constitution and by-laws of the Philippines, no

republic act or bill supporting euthanasia is yet to be accepted. The closest was

the bill introduced by the late Senator Miriam Defensor Santiago—the Senate Bill

1887 or the "Natural Death Act," which only seeks to legalize passive euthanasia

[33; Ager, 2013). Regarding bioethics, Philippine laws, and the country's revised

penal code, euthanasia in any form shall remain illegal by all means.

II. Discussion

Various studies highly oppose and question the code and conduct of

euthanasia, especially physician-assisted suicide (PAS), given the ethical misdeed

it promotes in medicine. The Hippocratic oath of physicians is one example that

exacerbates claims that euthanasia shall remain banned and prohibited. Based on

the study of Hetzler et al. (2019), 30% out of 1000 randomly chosen physicians in

the U.S. thought that legalizing PAS would lead to the legalization of all types of

euthanasia [14]. In addition, their result also suggests that 46% of physicians

agreed that the legalization of euthanasia would lead insurance companies to

invest in or prefer covering euthanasia rather than costly life-saving treatments.

Page 4 of 53
The results directed the study to conclude that there were disparities between the

willingness of physicians to endorse and practice physician-assisted euthanasia, or

PAS, given the bioethical codes they ought to follow. Based on the result of the

study mentioned above, together with other related literature and studies, the

researchers came up with the following arguments.

First Argument 

The Hippocratic Oath strongly opposes euthanasia because there is a line

from the oath that reckons euthanasia being unethical—forcing doctors to swear

never to "deliver a lethal medication to anybody if requested for it, nor...make a

proposal to that effect". Because the primary goal of medicine is to improve

patient quality of life, not shorten it, various medical associations reject assisted

suicide as well as physician-assisted suicide (PAS) for the reason that it is against

professional ethics. Almost all observers agree that active euthanasia, both

nonvoluntary and involuntary, is morally wrong since it terminates a patient's life

without their consent. Most religious people agree that good end-of-life care is far

preferable to euthanasia and that individuals who become vulnerable due to

disease or disability require special attention and protection.

In 400 B.C., the Greek doctor Hippocrates of Cos, regarded as the father

of medicine, wrote the Hippocratic Oath—which obeyed as a "canonical text of

medical ethics." As the pinnacle of strict ethical concepts in medicine, it is critical

to both the patient-physician relationship and maintaining high professional

morality [12]. It is an ethical rule attributed to the ancient Greek physician

Page 5 of 53
Hippocrates, has served as a standard of conduct for the medical community for

centuries, and is currently used at many medical schools' graduation ceremonies.

The collection included knowledge on medical topics and a set of guidelines for

medical educators and their students. The Hippocratic oath is a code, or a portion

of it, that has been passed down through generations of doctors. In the oath, the

physician pledges to prescribe only beneficial treatments according to his abilities

and judgment, to refrain from causing harm or hurt, and to live an exemplary

personal and professional life [3].

"Neither will I administer a poison to anybody when asked to do so, nor

will I suggest such a course"—these words of the Hippocratic Oath seem to be

quite obvious to forbid doctors from aiding in the suicide of their sick patients.

This conclusion has been contested, leading others to claim that what is intended

is a warning regarding using medications with dangerous adverse effects.

However, evidence suggests that Hippocratic doctors did not engage in what is

now known as assisted suicide [8].

The British Medical Association rejects assisted suicide because it

contravenes the ethics of professional practice, as the fundamental objective of

medicine is to improve patient quality of life, not to foreshorten it. To support the

legalization of euthanasia and PAS, this essential and profound distinction

between helping and hurting has been purposefully masked. In numerous regions,

it requires physicians to take the Hippocratic oath, and violating the oath's

principles has repercussions of suspension of medical practice or arrest. However,

recent opinions on whether euthanasia is compatible with the Hippocratic oath

Page 6 of 53
have begun to vary. Currently, many have begun to question whether euthanasia

and PAS violate the principles of the Hippocratic oath, which has been undertaken

by over 6 million doctors worldwide.

Most arguments state that euthanasia violates the Hippocratic oath and is

unethical because it breaches the basis of medical ethics that revolves solely

around the oath's two principles. The first principle of the oath states, "first, do no

harm". This delivery of lethal pharmaceuticals generates "maleficence". The

reason is that it harms by causing the body's organs to degrade and by simply

taking a human life in violation of the oath's clause that reads, "I will not give a

lethal drug to anyone if I am requested, nor will I suggest such a scheme".

Additionally, doctors eventually destroy and kill human life, and thus will break

the principles of "beneficence" and "nonmaleficence" by offering euthanasia and

PAS. Euthanasia and PAS are morally wrong and should thus be outlawed in

many nations, including the United Kingdom because they violate the Hippocratic

oath and fundamental medical ethics.

In light of this, there is enough evidence that Hippocratic Oath is firmly

against euthanasia, requiring physicians to swear never to "give a deadly drug to

anybody if asked for it, nor...make a suggestion to this effect" [21]. However, in

ancient Greece and Rome, PAS and euthanasia were commonplace. Samuel

Williams, a non-physician, made a pro-euthanasia speech in front of the

Birmingham Speculative Club in 1870. This speech sparked discussion about

legalizing euthanasia among American and British doctors in the late nineteenth

Page 7 of 53
century. In 1905, a bill to legalize euthanasia was introduced into the Ohio state

legislature.

Moreover, due to ambiguous wording, discussions about euthanasia are

often very confusing. Passive euthanasia, being widely acknowledged as ethical

and legal, is essentially recognized as the removal or withholding of

life-sustaining medical interventions. Increasing opioids to relieve a patient's pain,

even if doing so has the unintended consequence of hastening the patient's death,

is called indirect or passive euthanasia. Nearly all observers concur that

nonvoluntary and involuntary active euthanasia is immoral since it ends a patient's

life without their consent.

Physicians may feel conflicted about their obligation to relieve pain and

preserve life. The experiences of physicians in accepting and approving requests

for assisted suicide or euthanasia are not well recognized. Therefore, to examine

the worries, emotions, and pressure faced by physicians who receive requests for

assisted suicide or euthanasia, a cross-sectional study was carried out in 2016. A

total of 3000 random physicians were subjected to the said study. The sample

consisted of doctors who had provided adult patient care in the Netherlands over

the previous year. When questioned about the most recent instance in which they

denied a request for euthanasia or assisted suicide, half of the doctors responded

in the affirmative, and the other half in the negative [22]. Based on the same

study, 248 respondents provided information on an application for assisted suicide

or euthanasia that was denied, and 245 provided information on an approved

application. Physicians, who declined and approved a request for assisted suicide

Page 8 of 53
or euthanasia, frequently expressed concerns about particular parts of the

procedures, such as the emotional toll of planning and carrying out the operations.

Physicians, who declined a request often, felt pressured to comply, especially if

the patient was under 80 years old, had a life expectancy of fewer than six

months, and did not have cancer. Most medical professionals who aided in or

executed euthanasia reported conflicting feelings. The effects of requests for

assisted suicide and euthanasia on physicians should be understood by society.

Physicians' stress may make them less ready to perform assisted suicide and

euthanasia. In light of this, they should not be pressured to go against their moral

principles or be persuaded to perform assisted suicide and euthanasia in situations

that might not satisfy the requirements for proper care.

Following Articles 28.1 and 28.2 of our Code of Medical Ethics and

Deontology, physicians must fulfill their legitimate role in supporting and caring

for their dying patients by sharp pain and distress management. He or she should

try for the maximum possible material well-being; he or she should provide

spiritual attendance and personal comfort to the dying, depending on the

circumstances; and he or she should also help the dying person's relatives. When

he refrains from painful and unjustifiable therapies and suspends them because

they are no longer helpful, the physician also dignifies death and financial aid.

However, killing a sick person or assisting in his suicide would betray his

profession as a healer and guardian of human life. A physician should never

purposefully cause death; that is not what medicine is. Even if the patient, his or

her family, a hospital care provider, a committee, or the law permits it, a doctor

Page 9 of 53
may never exercise the given authority and prerogatives by society to carry out a

death sentence mandated by a court of law or to end the life of a sick person [13].

Religious groups in the Philippines oppose the legalization of euthanasia,

although it helps patients who opt for it to end their excruciating suffering from

incurable and fatal conditions. However, there have been various instances of

uncertainty when weighing the pros and cons of legalizing euthanasia. Taking

England as an example, the constant shift in attitudes of the British Medical

Association and Royal College of Physicians from strict opposition to neutrality

and vice versa demonstrates that it is difficult for them to accept any attitude

regarding euthanasia and to maintain any consistent attitude [4].

Some opponents see PAS as unethical because it violates the Hippocratic

Oath of "doing no harm," as causing harm to patients is not a healing proposition

[5]. Opponents of PAS may object because violating the Hippocratic Oath may

lead to a decrease in trust in the patient-physician relationship, for ending a

human life is considered to devalue life. As a result, eliminating a human life to

reduce the cost of health care or because suffering and terminal illness are

inconvenient, as proponents argue, disregards the value of life. Another quandary

in legalizing euthanasia is how the medical profession will begin to teach medical

students and residents how and when it is appropriate to end a human life. If not

all physicians hold the same views on this issue, it is necessary to require

physicians to be trained in moral reasoning and problem-solving.

Page 10 of 53
Second Argument 

The chances of having euthanasia legalized in the Philippines are slim,

given that Christian or Roman Catholic beliefs dominate

the country. In addition, as the 1987 Philippine Constitution does not contain any

language referring to a "right to death" or anything similar, a law in the nation has

not yet been passed allowing for mercy killing or euthanasia. Furthermore, no law

that promotes euthanasia, whether passive or the discontinuation of

life-prolonging care, has been accepted or advanced to the third reading.

Legalizing euthanasia in the Philippines would highly contradict various laws,

codes, and conducts that were predominantly followed and established throughout

the years.

Euthanasia or Mercy-killing was a long-running topic in the Philippines.

Filipinos have different views and ideologies regarding euthanasia, considering

that we are a democratic country. It is a complicated subject that gives freedom of

choice in discussing human life. Fernando (2019) stated, "euthanasia has a noble

intention, but it is never our call to decide who and when to die. Mercy killing is

against the dignity or sanctity of human life whether it is voluntary or

nonvoluntary" [38]. Although it has a good purpose, it is said to be unethical

regarding human rights and contradicts the constitution. He added that people do

not pass judgment on who should live and when they should die. According to

Article II, Section 11 of the Philippine Constitution from 1987, the State upholds

the dignity of every individual. It ensures that their rights are fully respected.

Euthanasia is, therefore, in opposition to both the Philippine Constitution and the

Page 11 of 53
Hippocratic oath that says, "To please no one will I prescribe a deadly drug nor

give advice which may cause his death" [20].

Moreover, based on Section one of Article III, also known as the 1987

Philippine Consitution bill of rights, "No person shall be deprived of

life…without due process of law…". The article implies that by any means, any

law constituting the termination of life might be acceptable by following due

statutory conducts or processes if there is one [34]. However, in the case of the

Philippines, no law or legislation provides a right to have any person decide on

others or their manner of death. Instead, the country strictly follows Act no. 3185,

also known as The Revised Penal Code, where any action of harming or killing

others or assisting another to commit suicide—under Article 248 and Article 253,

respectively, is punishable by law, and anywho commits such actions are deemed

liable to criminal offenses [23].

Adding to that, according to Dayrit et al. (2018, p. 220), euthanasia is still

illegal, despite the fact that since the 1980s, when a movement towards palliative

and hospice care emerged, more and more medical professionals have used it as a

source of opinion. However, religion is a significant factor in everything said

above. With around 80% of Filipinos identified as Catholic, the majority of

Filipino are pro-life, which opposes abortion and euthanasia [6].

In the Philippines, euthanasia usually becomes controversial whenever

mentioned in the Senate. As published in the British Medical Journal, the

Philippines considered its first Euthanasia bill by 1997 as part of a 16-point bill of

rights for patients [19]. The controversy made headlines since the Philippines

Page 12 of 53
would be the first Catholic country to legalize euthanasia if the bill was ratified

and incorporated into law. However, it only managed to undergo the first reading,

given that many opposed the idea of its implementation. As stated by then-Senate

Health Committee Secretary John Basa, the said bill would create a new world for

doctors—since if they try to aid a patient to die before its legalization, they could

be charged with malpractice and be liable to imprisonment. The secretary also

emphasized that the bill only seeks to legislate passive euthanasia, albeit still

contentious due to religious beliefs.

Moreover, there is tremendous pressure from the Catholic Church as it

highly influences 86% of the Philippine population regarding perspective and

religious beliefs [32]. According to Monsignor Pedzro Quitorio, the spokesman

for the Catholic Bishops' Conference of the Philippines, such an act of omission

to cause death and eliminate suffering (by oneself or by intention) constitutes

murder—disrespecting the life given by His Creator [19]. The bill was

immediately rejected, not only because of religious beliefs but due to the gaps

within the Philippine constitution.

Legalizing passive euthanasia was only re-introduced by the late Senator

Miriam Defensor Santiago during the first regular session of the Thirteenth

Congress of the Republic of the Philippines. It was first recognized as Senate Bill

2008, also known as the Natural Death Act of 2005. The bill aims to recognize the

right of adult persons to decide their health care, such as withholding or

withdrawing life-sustaining treatment in cases of a terminal condition or

permanent unconscious condition [33]. Multiple attempts were made in congress

Page 13 of 53
to legalize passive euthanasia within the country. Senator Miriam Defensor

Santiago kept passing the bill until the first regular session of the Sixteenth

Congress of the Republic of the Philippines. This time, it was re-introduced as the

Senate Bill 1887 or the Natural Death Act, with the same aim of recognizing the

fundamental right of adults to decide whether to withhold or withdraw

life-sustaining treatment in case of terminal or permanent unconscious condition

[33].

In addition, the present legal system of the Netherlands went into effect in

2001. The Supreme Court's euthanasia guidelines were defined in the Termination

of Life on Request and Assisted Suicide (Review Procedures) Act of 2001,

permitting an appeal based on the necessity defense. The Act amends sections 293

and 294 of the Dutch Criminal Code. Subsection 2 of Sections 293 and 294 states

that euthanasia or assisted suicide is not unlawful if and when a doctor, who

fulfilled a death request, has adhered to the due care criteria set out in the Act. To

adhere to due care under Section 2 means:

a) the patient's request to die must be voluntary;

b) the doctor must be sure that the request is well-considered;

c) must have been convinced that the patient's suffering was both hopeless

and unbearable;

d) the doctor must have carried out the euthanasia, or assisted with the

suicide, with due care; and

e)The patient must have been seen by at least one impartial doctor, who

must have given his opinion, in writing, about the first four criteria.

Page 14 of 53
 In addition to the proper care standards, there is a reporting standard that

mandates that when a doctor ends a patient's life, the doctor must contact the

coroner and report the details of the death to one of five regional review

committees. When deciding whether to bring legal action against the doctor, the

committee (which must include at least one attorney, one physician, and an

ethicist) must submit a report to the Public Prosecution Service (Vres, 2004) [17].

However, according to Groenewoud et al. (2021), the Netherlands' death rate rose

from 1.9% in 1990 to 4.4% in 2017 due to the legalization of all kinds of

euthanasia. Their cross-sectional studies proved that throughout the 28 years of

legislating euthanasia in the Netherlands, specifically physician-assisted suicide,

the country experienced a considerable amount of unexplained incidence of the

practice throughout its regions. They claimed that this might be due to the

underuse, overuse, or misuse of euthanasia which might become the case for other

countries who plan to legalize the practice [11]. Other than that, a published

article revealed that the cases of euthanasia in the Netherlands significantly rose

from 1,882 reported cases in 2002 to 6,091 cases in 2016—implying that the

number of euthanasia cases doubled within ten years of its legislation and tripled

after 15 years. Albeit, 83% of these reported cases were of euthanizing patients

who are terminally ill or incurable. The remaining percentages were allocated to

ailments not following the established legal requirements—such as multiple

pathologies, disabilities due to old age, psychiatric disorders, and dementia [24].

Page 15 of 53
Third Argument 

The researchers claimed euthanasia is a heinous crime, such as assisted

suicide, that results in murder as it was based on the revised penal code of the

Philippines. It could be identified as murder as it unlawfully takes someone's life.

In contrast, it is against Article 253 under chapter one of Section One—Parricide,

murder, and homicide which implies that anyone who aids another person in

killing themselves faces the punishment of prision mayor. If a person drives his

aid to another to the point of suicide, he confronts the punishment of temporary

exclusion. After all, the state and doctors must preserve life while providing care

without endangering patients. As a result, in a welfare state, there should be no

role for euthanasia.

Assisted suicide and euthanasia have always been interconnected as their

purpose is to alleviate the victim's or patient's pain and suffering. Based on

Graham & Prichard (2013), those two are examples of assisted death. In general,

assisted suicide is when a person has been prescribed drugs that they must take

themselves to die [39]. In contrast, euthanasia refers to a condition in which the

person seeking assistance to die has someone else take the action that leads to

their unnatural death (such as injecting a lethal drug). Technically, euthanasia

happens when a patient is deliberately taken life by the accompanying physician

or nurse practitioner. Nevertheless, when a person actively attempts suicide with

the assistance of a doctor or nurse practitioner who is present and administers the

medicine themself, this is known as assisted suicide.

Page 16 of 53
 Conforming to Zhongq (2019), The line between the two courses of

action, euthanasia, and murder, is ambiguous because of the two points they have

in common [40]. First, most of the world's nations prohibit both murder and

euthanasia. If someone chooses to do either of the deeds, they shall know that the

legislation will investigate them until the "murderer" is given the proper penalties.

Second, using equipment to kill another individual and acting out until that person

dies are practically the same actions in both euthanasia and murder. Euthanasia

may sometimes be regarded as constructive and reasonable since it allows patients

to die peacefully and painlessly; however, even if the killing is painless, it does

not alter the fact that another is taking someone's life.

In addition, as stated by the National Library of Medicine (2014), direct

euthanasia is forbidden. It is considered the same as murder in all Islamic nations.

euthanasia is not mentioned explicitly in Iranian legal documents. Still, numerous

exclusions result in a more severe punishment in particular murder situations.

However, euthanasia, derived from Muslim Islamic philosophy, is premeditated

murder. According to research done on 55 doctors, 98% believe that

physician-assisted suicide and euthanasia are violations of human dignity.

Counter Argument 

In the case of the Hippocratic oath, there are still studies that argue how, in

certain situations, providing euthanasia is the best solution to help a patient. Spina

(2019) claims that the Hippocratic Oath does not specify nor oblige physicians to

preserve life; however, it takes and at all costs. In any sense, physicians should

Page 17 of 53
not be committed to prolonging life—they should "help" the sick and not "injure"

them further through life-sustaining treatments without reassurance. However,

performing any act of mercy killing or euthanasia is still incompatible with

physicians' roles in society. Their participation in suicide (primarily through PAS)

undermines the integrity of physicians—" to heal and not to harm" and may

correspond to patients losing trust [17, 18].

Moreover, modern technology provides other alternatives to alleviating

pain and suffering rather than getting euthanized. Palliative care and hospice care

are among the most common measures used globally. Palliative care is considered

the best countermeasure, and why euthanasia should not be legislated in any case.

This specialized medical care provides for people with terminal illnesses to

enhance their quality of life and help them understand and decide on the preferred

medical treatment [25, 36]. On the other hand, hospice care is intended for people

whose life expectancy is six months or less. Its main point is to give the best

quality of life possible for a patient for their remaining time—not as a form of

cure for any disease [30]. Based on an article from the United States Conference

of Catholic Bishops (n.d.), various prominent medical organizations highly

oppose the practice of euthanasia as it invalidates the distinction between intended

and unintended effects of treatments—" to kill the pain, not the patient [28]."

They argue that given the availability of practicing palliative and hospice care,

there is no need for hastily ending the life of another, which will forever be an

immoral and unethical act.

Page 18 of 53
It is also notable that the Philippine Senate once considered legalizing euthanasia,

specifically passive euthanasia, throughout the country. Similar to the

Netherlands—the first country to legalize euthanasia in any form, the proposed

bill imposing the practice had specific statutory rules aligned with the patient's

decision to continue suffering or die in peace instead. The said bill specifically

claims that patients should have the right to refuse life-sustaining treatments or

not to suffer and die with dignity. Based on the excerpt of the Natural Death Act,"

[The] prolongation of the process of dying for persons with a terminal condition

or permanent unconscious condition may cause loss of patient dignity, and

unnecessary pain and suffering while providing nothing medically necessary or

beneficial to the patient"—claiming that the primary intent of imposing passive

euthanasia was to alleviate the pain of patients. Moreover, Section 2 of the bill

declares that it is the state's policy to value and respect every person's dignity and

human rights, such as their right to decide on health care. The bill also has

multiple directives for health institutions or attending physicians to validate and

acknowledge the patient's decision. Meanwhile, Section 6 of the bill imposes the

liability and immunity of health care providers and facilities from "legal, civil,

criminal, or professional conduct sanctions, unless otherwise negligent"—which

was on similar terms with the Dutch law that any action with the intent of ending

a life is a criminal offense except when a physician fulfills the "statutory due care

criteria" of euthanizing a patient from suffering, without hopes of improvement or

cure [33, 35].

Page 19 of 53
 However, despite the said bill being ideal for most people to end their

nonsensical suffering, there are still underlying issues that one must observe and

assume—given that euthanasia is a practice that promotes killing rather than

healing, something that could be easily abused and overused. As mentioned

earlier, euthanasia has brought multiple discrepancies in its implementation within

the Netherlands. The practice of PAS became normalized to the point that the

recorded cases of euthanasia within the region significantly rose from 4,188 in

2012 to 7,000 in 2017 [25]. Based on the same article, the hike in cases of PAS

reformed the country to open an investigation into some questionable cases of

euthanasia. Examples are those who were euthanized although they suffer from

psychiatric conditions such as Alzheimer's and dementia, making it difficult to

ascertain if such patients voluntarily requested their deaths. Another study

supports the claim that the Netherlands experienced such discrepancies among

cases of euthanasia due to the underuse, overuse, or misuse of the practice, which

might become the same case for other countries that plan to legalize it. Euthanasia

has increased the country's mortality rate from 1.9% in 1990 to 4.4% in 2017, at

an alarming rate of tripled cases for 15 years since its legalization in the

Netherlands [11, 24].

In other cases, euthanasia is not viewed as either murder or suicide but rather

as a right to death with dignity. Active euthanasia supporters often contend that

killing patients is not worse than allowing them to die. Patients should have the

freedom to live as they choose, as stated by proponents of voluntarily ending

patients' lives. Mercy-killing proponents contend that letting patients die in

Page 20 of 53
vegetative states with no chance of recovery eliminates further unnecessary and

pointless medical interventions. Killing them would stop any more misery if they

were already experiencing it. Supporters of PAS contend that by offering

assistance to a suffering or terminally ill patient, a doctor only facilitates the

patient's desire to pass away in dignity.

In the case of Diane Pretty, a 43-year-old woman diagnosed with motor

neuron disease, she was paralyzed neck down. Mrs. Pretty has almost no

intelligible speech and is tube-fed. Her life expectancy is extremely low and only

measured in weeks or months. Her reasoning skills and intelligence, however, are

unaffected. The disease's last phases are incredibly unpleasant and humiliating.

She desires to be able to decide how and when she dies to avoid the anguish and

indignity she would experience if this continues. Since she cannot commit suicide

herself, she wants her husband, Brian Pretty, to assist her suicide without

worrying about being prosecuted. Though it is not illegal in England to commit

suicide, the applicant's illness prevents her from doing it on her own. However,

according to Section 2(1) of the Suicide Act of 1961 in the United Kingdom, it is

illegal to aid someone else in committing suicide. It leads Diane Pretty to bring

her case to the court and reach the House of the Lords, the highest court at that

time. However, her case was rejected in the high court, and her appeals were

dismissed. Diane Pretty continued to suffer from her illness until she died (CASE

OF PRETTY v. THE UNITED KINGDOM, 2002). In a similar case in the

Philippines, an act of assisting suicide is punishable by law. According to Doyal

(2001), Active Euthanasia or physician-assisted suicide should be acknowledged

Page 21 of 53
 legally—either by new legislation or by a more forthright judiciary's

interpretation of the law already in effect. Active euthanasia should be legalized

for people with the same case, like Diane Pretty, who is permanent and severely

incompetent. The author argues that Active euthanasia is morally right if it is in

the patient's best interest [10]. If certain patients' needs are satisfied by death or if

the discontinuation of life-sustaining treatment may be acceptable, death

represents a moral good for these individuals as they will suffer less.

However, the Catholic Bishops' Conference of England and Wales stated that

the idea that human life was a gift from God that was accepted in trust was a

fundamental part of the Catholic faith. Even with the agreement, acts intended to

murder oneself or others reveal a devastating misunderstanding of what it means

to be a human. They further mentioned, "Suicide and euthanasia were outside the

range of morally acceptable options in dealing with human suffering and dying"

(CASE OF PRETTY v. THE UNITED KINGDOM, 2002) [26]. Considering that

80% of Filipinos are Catholics, and the other 20% may have their own belief and

views about euthanasia, the majority of them may oppose the concept of

Euthanasia in the Philippines. Those who oppose euthanasia frequently claim that

killing is never morally right and that voluntary or involuntary euthanasia violates

patients' rights of "no harm."

III. Conclusion
Most Filipinos and the Philippine government cannot entirely embrace and

favor euthanasia legalization in the country. There are various factors why the

country's legalization of euthanasia ought to be null and illegal. Euthanasia, in

Page 22 of 53
many views and aspects, is unethical. Performing euthanasia was unethical from

the standpoint of the religious group and the point of the Hippocratic oath and the

fundamentals of medical ethics. As generalists have pledged to do no harm and

preserve all beings' lives, it is a big deal for them to commit an act that goes

against their moral values as medical professionals. Physician-assisted suicide

(PAS) or euthanasia breaches a series of laws, codes, and acts punishable under

Philippine law. As there were also multiple attempts to legalize it to congress,

legal actions against the participants involved are still imparted in this practice

and labeled murderers. It is where the fact that another is taking someone's life

does not change, even if the killing is painless. From the perspective of the

nation's residents, the state, and the religion, euthanasia will continue to be

unlawful and unethical. On this basis, future researchers may propose palliative

and hospice care as conventional measures for the ill-patients that are more

acceptable and ethical than euthanasia— investing more in research to develop

better implements and procedures for improving the quality of care and holding

healthcare organizations accountable for consideration at the end of life.

Page 23 of 53
IV. References

Electronic Documents
Article in Online Encyclopedia
[1] B. Garcia & K. Brind’Amour. “Evangelium Vitae [1995], by pope John Paul
II” in The Embryo Project Encyclopedia. The Embryo Project at Arizona State
University, [online document], 2007. Available: The Embryo Project
Encyclopedia,
https://embryo.asu.edu/pages/evangelium-vitae-1995-pope-john-paul-ii
[Accessed: Nov. 16, 2022].
[2] ProCon. “Historical Timeline: History of Euthanasia and Physician-Assisted
Suicide” in ProCon/Encyclopedia Brittanica. Encyclopedia Britannica, Inc.,
[online document], 2022. Available: ProCon/Encyclopedia Brittanica,
https://euthanasia.procon.org/historical-timeline/ [Accessed: Nov. 16, 2022].
[3] W. D. Smith, “Hippocrates,” Encyclopædia Britannica. [Online]. Available:
https://www.britannica.com/biography/Hippocrates. [Accessed: November 15,
2022].

Journal Article Abstract (accessed from online database)

[4] G. Bosshard , B. Broeckaert , D. Clark , L.J. Materstvedt , B. Gordijn , H.C.
Müller-Busch [2008]. "A Role for Doctors in Assisted Dying? An Analysis of
Legal Regulations and Medical Professional Positions in Six European
Countries," J Med Ethics, 34[1]: 28–32;Feb 2017.[PubMed] [GoogleScholar]
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5402774/. [Accessed: Nov.
18, 2022]
[5] J.D. Boudreau. Physician-assisted suicide and euthanasia: can you even
imagine teaching medical students how to end their patients’ lives? Perm J
2011;15[4]:79–84[Abstract]
https://pulmonarychronicles.com/index.php/pulmonarychronicles/article/view/
561/1236 . [Accessed: Nov. 18, 2022]
[6] M. M Dayrit, L. P. Lagrada, O. F. Picazo, M. C. Pons, and M. C. Villaverde,
“The Philippines Health System Review,” New Delhi: World Health
Organization, vol. 8 no. 2, 2018. Available:
https://apps.who.int/iris/rest/bitstreams/1151742/retrieve [Accessed: Nov. 18,
2022].
[7] J.Ellis (2022, October 25). Which countries have legalized euthanasia? My
Law Questions.
https://www.mylawquestions.com/which-countries-have-legalized-euthanasia.

Page 24 of 53
 htm. [Accessed: Nov. 18, 2022]

Journal Article in Scholarly Journal (published free of charge on the Internet)

[8] R. Ahlzen, “Suffering, authenticity, and physician Assisted Suicide,”
Medicine, Health Care and Philosophy, vol. 23, no. 3, pp. 353–359, 2020.
[Online serial]. Available: https://doi.org/10.1007/s11019-019-09929-z.
[Accessed November 18, 2022]
[9] B. Banović and V. Turanjanin, “Euthanasia: Murder or Not: A Comparative
Approach,” Iranian journal of public health, vol. 43, no. 10, pp. 1316–23, Oct.
2014, Accessed: Nov. 22, 2022. [Online]. Available:
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4441884/
[10] L. Doyal and L. Doyal, “Why active euthanasia and physician assisted suicide
should be legalised,” The BMJ, 10-Nov-2001. [Online]. Available:
https://doi.org/10.1136/bmj.323.7321.1079. [Accessed: 28-Nov-2022].
[11] A. S. Groenewoud, F. Atsma, M. Arvin, G. P. Westert, and T. A. Boer,
“Euthanasia in the Netherlands: a claims data cross-sectional study of
geographical variation,” BMJ Supportive & Palliative Care, p.
bmjspcare-2020-002573, Jan. 2021, doi: 10.1136/bmjspcare-2020-002573.
[12] P. B. Hanák, K. Ivanová, and M. Chráska, “Analyzing the semantic space of
the hippocratic oath,” Open Medicine, vol. 14, no. 1, pp. 683–693, 2019.
[Online]. Available: https://doi.org/10.1515/med-2019-0079. [Accessed
November 18, 2022].
[13] G. Herranz, “Lectures on medical ethics. Unit of Humanities and Medical
Ethics - unit of Humanities and Medical Ethics,” Humanities and Medical
Ethics Unit. [Online]. Available:
https://en.unav.edu/web/humanities-and-medical-ethics-unit/bioethics-material
/conferencias-sobre-etica-medica-de-gonzalo-herranz. [Accessed: November
15, 2022].
[14] P. T. Hetzler, J. Nie, A. Zhou, and L. S. Dugdale, “A Report of Physicians’
Beliefs about Physician-Assisted Suicide: A National Study,” The Yale
Journal of Biology and Medicine, vol. 92, no. 4, pp. 575–585, Dec. 2019,
Accessed: Nov. 22, 2022. [Online]. Available:
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6913834/
[15] J. Jakhar, S. Ambreen, and S. Prasad, “Right to Life or Right to Die in
Advanced Dementia: Physician-Assisted Dying,” Frontiers in Psychiatry, vol.
11, Jan. 2021, doi: 10.3389/fpsyt.2020.622446.
[16] S. B. Math and S. K. Chaturvedi, ”Euthanasia: right to life vs right to die,”
The Indian Journal of Medical Research, vol. 136, pp. 899-902, 2012.

Page 25 of 53
 [Online]. Available: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3612319/
[Accessed: Nov. 16, 2022].
[17] D. P. Sulmasy, J. M. Travaline, L. A. Mitchell, and E. W. Ely,
“Non-Faith-Based Arguments against Physician-Assisted Suicide and
Euthanasia,” The Linacre Quarterly, vol. 83, no. 3, pp. 246–257, Aug. 2016,
doi: 10.1080/00243639.2016.1201375.
[18] Ubaldus dr Vries A Dutch Perspective: The Limits of Lawful Euthanasia, 13
Annals Health L. 365 (2004). Available at:
http://lawecommons.luc.edu/annals/vol13/iss2/4
[19] C. Wallerstein, “Philippines considers euthanasia bill,” BMJ, vol. 314, no.
7095, p. 1641, Jun. 1997, doi: 10.1136/bmj.314.7095.1641i.
[20] P. A. Pecorino, “Euthanasia,” Social Context, 2002. [Online]. Available:
https://www.qcc.cuny.edu/socialsciences/ppecorino/medical_ethics_text/Chapt
er_11_Termination_of_Life/Social_Context.htm#:~:text=Hippocrates%20men
tions%20euthanasia%20in%20the,that%20life%20needed%20to%20be.
[Accessed: 26-Nov-2022].

Newspaper Article from the Internet

[21] E.J. Emanuel ,S. Joffe , “Assisted Suicide and Euthanasia”. Holland-Frei
Cancer Medicine. 6th edition. Hamilton (ON): BC Decker; 2003. [Online].
Available: https://www.ncbi.nlm.nih.gov/books/NBK13381/. [Accessed:
November 15, 2022].
[22] K. Evenblij, et al. (2019) “Physicians’ experiences with euthanasia: A
cross-sectional survey amongst a random sample of Dutch physicians to
explore their concerns, feelings and pressure,” BMC Family Practice, 20(1).
Available: https://doi.org/10.1186/s12875-019-1067-8. [Accessed: November
15, 2022].

Internet Documents
Professional Internet Site
[23] “Act No. 3815, s. 1930,” Official Gazette of the Republic of the Philippines,
Dec. 08, 1930.
https://www.officialgazette.gov.ph/1930/12/08/act-no-3815-s-1930/ [Accessed
Nov. 24, 2022].
[24] Alliance Vita, “Euthanasia in the Netherlands - Alliance VITA,” Alliance
VITA, Nov. 24, 2017.
https://www.alliancevita.org/en/2017/11/euthanasia-in-the-netherlands/

Page 26 of 53
 [Accessed Nov. 22, 2022].
[25] D. Boffey, “Dutch prosecutors to investigate euthanasia cases after sharp rise,”
The Guardian, Mar. 12, 2018.
https://www.theguardian.com/world/2018/mar/12/dutch-prosecutors-investigat
e-euthanasia-cases-sharp-rise-docter-assisted-deaths-netherlands [Accessed
Nov. 25, 2022].
[26] European Court of Human Rights, “Case of Pretty v. the United Kingdom,”
HUDOC.European Court of Human Rights, 2002. [Online]. Available:
https://hudoc.echr.coe.int/eng#{%22itemid%22:[%22001-60448%22]}.
[Accessed: Nov 26, 2022].
[27] BBC, “Ethics - euthanasia: Ethical problems of euthanasia,” BBC (British
Broadcasting Corporation), n.d. [Online]. Available:
https://www.bbc.co.uk/ethics/euthanasia/overview/problems.shtml. [Accessed:
26-Nov-2022].
[28] “Killing the Pain, Not the Patient: Palliative Care vs. Assisted Suicide |
USCCB,” United States Conference of Catholic Bishops.
https://www.usccb.org/prolife/killing-pain-not-patient-palliative-care-vs-assist
ed-suicide [Accessed Nov. 25, 2022].
[29] N. Davis, “Euthanasia and assisted dying rates are soaring. But where are they
legal?,” The Guardian, Jul. 15, 2019.
https://www.theguardian.com/news/2019/jul/15/euthanasia-and-assisted-dying
-rates-are-soaring-but-where-are-they-legal [Accessed Nov. 22, 2022].
[30] “Hospice care: Comforting the terminally ill,” Mayo Clinic, 2019.
https://www.mayoclinic.org/healthy-lifestyle/end-of-life/in-depth/hospice-care
/art-20048050 [Accessed Nov. 25, 2022].
[31] J. Miller, “Religion in the Philippines,” Asia Society, 2022.
https://asiasociety.org/education/religion-philippines#:~:text=The%20Philippi
nes%20proudly%20boasts%20to [Accessed Nov. 22, 2022].
[32] “Natural Death Act of 2005,” Senate of the Philippines, May 30, 2005.
https://legacy.senate.gov.ph/lisdata/34342743!.pdf [Accessed Nov. 24, 2022].
[33] “Natural Death Act,” Senate of the Philippines, Nov. 06, 2013.
http://legacy.senate.gov.ph/lisdata/1812315368!.pdf [Accessed Nov. 24,
2022].
[34] Official Gazette, “The Constitution of the Republic of the Philippines,”
Official Gazette of the Republic of the Philippines, 1987.
https://www.officialgazette.gov.ph/constitutions/1987-constitution/ [Accessed
Nov. 24, 2022].
[35] W. en S. Ministerie van Volksgezondheid, “Euthanasia - Government.nl,”

Page 27 of 53
 Government of the Netherlands, Aug. 25, 2011.
https://www.government.nl/topics/euthanasia#:~:text=Under%20Dutch%20la
w%2C%20any%20action [Accessed Nov. 22, 2022].
[36] National Institute on Aging, “What Are Palliative Care and Hospice Care?,”
National Institute on Aging, May 14, 2021.
https://www.nia.nih.gov/health/what-are-palliative-care-and-hospice-care
[Accessed Nov. 22, 2022].

General Internet Site

[37] J. Cadungon, "Euthanasia in the Philippines," WordPress.com, para. 4, Sept.
8, 2013. [Online]. Available: https://jirocadungon.wordpress.com/.
[Accessed Nov. 16, 2022].
[38] S. Fernando, " Euthanasia" sunstar.com, para 8. Sept. 11, 2019 [Online]
Available:https://www.sunstar.com.ph/article/1822738/baguio/opinion/fernand
o-euthanasia. [Accessed Nov. 28, 2022]

Personal Internet Site

[39] H. Graham & J. Prichard, “Voluntary Euthanasia and 'Assisted Dying' in
Tasmania: A Response to Giddings and McKim.” October, 2013. [Online].
Available:
http://tc3.org.au/Media/Voluntary%20Euthanasia%20and%20Assisted%20Dyi
ng%20in%20Tasmania%20-%20A%20Response%209-10-13.pdf

Internet Newsgroup
[40] Zhongq, “The similarities and differences between euthanasia and murder,”
USENET: shorturl.at/afJL6, February 20, 2019. [Accessed: November 18,
2022].

Page 28 of 53
 Appendices

A. Curriculum Vitae

Page 29 of 53
Page 30 of 53
Page 31 of 53
Page 32 of 53
Page 33 of 53
Page 34 of 53
Page 35 of 53
Page 36 of 53
Page 37 of 53
Page 38 of 53
Page 39 of 53
Page 40 of 53
Page 41 of 53
Page 42 of 53
Page 43 of 53
Page 44 of 53
Page 45 of 53
Page 46 of 53
Page 47 of 53
Page 48 of 53
Page 49 of 53
Page 50 of 53
B. Plagiarism Scan Reports
Check the plagiarism percentage of your work through the attached links. Screenshot the
result and paste it here. Allowed percentage for plagiarism is 15% -20% only.

Site Result

Page 51 of 53
Page 52 of 53