G.R. No. L-45987 Case Digest

G.R. No. L-45987 May 5, 1939

People of the Philippines, plaintiff-appellee

vs Cayat, defendant-appellant

Ponente: Moran

Facts:

Cayat is a native of Baguio prosecuted for violation of Act No. 1639 and was sentenced by the justice of the peace of Baguio to pay a fine or suffer subsidiary imprisonment in case of insolvency.

On January 25, 1937, the City of Baguio accused Cayat of illegally possessing a gin, which the members of his tribe have been accustomed themselves to make prior to the passage of Act No. 1639.

Cayat interposed a demurrer which was overruled. At the trial, Cayat admitted the alleged facts but pleaded not guilty. But trial court found him guilty and sentenced him of the fine or imprisonment.

Cayat challenges the constitutionality of the Act on the following grounds: (1) That it is discriminatory and denies the equal protection of the laws;

(2) That it is violative of the due process clause of the Constitution: and.

(3) That it is improper exercise of the police power of the state.

Held:

It is an established principle of constitutional law that the guaranty of the equal protection of the laws is not equal protection of the laws is not violated by a legislation based on reasonable classification. And the classification, to be reasonable, (1) must rest on substantial distinctions; (2) must be germane to the purposes of the law; (3) must not be limited to existing conditions only; and (4) must apply equally to all members of the same class.

(1) Substantial Distinction: . It is not based upon "accident of birth or parentage," as counsel to the appellant asserts, but upon the degree of civilization and culture. "The term 'non-Christian tribes' refers, not to religious belief, but, in a way, to the geographical area, and, more directly, to natives of the Philippine Islands of a low grade of civilization, usually living in tribal relationship apart from settled communities." This distinction is unquestionably reasonable, for the Act was intended to meet the peculiar conditions existing in the non-Christian tribes.

(2) Germane to the purpose of law: it is unquestionably designed to insure peace and order in and among the non-Christian tribes. It has been the sad experience of the past, as the observations of the lower court disclose, that the free use of highly intoxicating liquors by the non-Christian tribes have often resulted in lawlessness and crimes, thereby hampering the efforts of the government to raise their standard of life and civilization.

(3) it must not be limited to conditions: The law is not limited in its application to conditions existing at the time of its enactment. It is intended to apply for all times as long as those conditions exist.

(4) apply to all members of the class: that the Act applies equally to all members of the class is evident from a perusal thereof. That it may be unfair in its operation against a certain number non-Christians by reason of their degree of culture, is not an argument against the equality of its application.

Act No. 1639, as above stated, is designed to promote peace and order in the non-Christian tribes so as to remove all obstacles to their moral and intellectual growth and, eventually, to hasten their equalization and unification with the rest of their Christian brothers. Its ultimate purpose can be no other than to unify the Filipino people with a view to a greater Philippines.