People vs. Cayat

68 Phil. 12 (1939)

 

Facts/Issue: Accused Cayat, a native of Baguio, Benguet, Mountain Province, and a member of the non-Christian tribes, was found guilty of violating sections 2 and 3 of Act No. 1639 for having acquired and possessed one bottle of A-1-1 gin, an intoxicating liquor, which is not a native wine. The law made it unlawful for any native of the Philippines who is a member of a non-Christian tribe within the meaning of Act 1397 to buy, receive, have in his possession, or drink any ardent spirits, ale, beer, wine or intoxicating liquors of any kind, other than the so-called native wines and liquors which the members of such tribes have been accustomed to prior to the passage of the law. Cayat challenges the constitutionality of Act 1639 on the grounds that it is discriminatory and denies the equal protection of the laws, violates due process clause, and is an improper exercise of police power.

 

Held: It is an established principle of constitutional law that the guaranty of the equal protection of the laws is not violated by a legislation based on reasonable classification. (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.

 

Act No. 1639 satisfies these requirements. The classification rests on real or substantial, not merely imaginary or whimsical distinctions. It is not based upon “accident of birth or parentage,” as counsel for 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.” (Rubi vs. Provincial Board of Mindora, supra.) This distinction is unquestionably reasonable, for the Act was intended to meet the peculiar conditions existing in the non-Christian tribes.

 

The prohibition enshrined in Act 1397 is designed to insure peace and order in and among non-Christian tribes. It applies equally to all members of the class evident from perusal thereof. That it may be unfair in its operation against a certain number of non-Christians by reason of their degree of culture, is not an argument against the equality of its application.