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Mary Concepcion Bautista and her husband are assailing the constitutionality of Letter of Instruction No. 869 (LOI) issued in 1979 which classified vehicles into Heavy and Extra Heavy. The LOI further banned these vehicles during weekends and holidays from 5am Saturday until 5am Monday. Purpose of this law was to curb down petroleum consumption as bigger cars consume more fuel. Pursuant to the LOI, Alfredo Juinio, then the Minister of Public Works, together with other cabinet members issued a circular implementing the LOI. Bautista claimed the LOI to be discriminatory as it made an assumption that Heavy and Extra Heavy cars are heavy on petroleum consumption when in fact there are smaller cars which are also big on fuel consumption. Further, the law restricts their freedom to enjoy their car while others who have smaller cars may enjoy theirs. Bautista avers that there is no rational justification for the ban being imposed on vehicles classified as heavy (H) and extra-heavy (EH).
ISSUE: Whether or not the LOI violates equal protection.
HELD: No. The SC held that Bautista was not able to make merit out of her contention. The Supreme Court ruled that the measure was a valid exercise of police power. Anent the issue on equal protection, the classification of cars on its face cannot be characterized as an affront to reason. The ideal situation is for the law’s benefits to be available to all, that none be placed outside the sphere of its coverage. Only thus could chance and favor be excluded and the affairs of men governed by that serene and impartial uniformity, which is of the very essence of the idea of law. The actual, given things as they are and likely to continue to be, cannot approximate the ideal. Nor is the law susceptible to the reproach that it does not take into account the realities of the situation. . . . To assure that the general welfare be promoted, which is the end of law, a regulatory measure may cut into the rights to liberty and property. Those adversely affected may under such circumstances invoke the equal protection clause only if they can show that the governmental act assailed, far from being inspired by the attainment of the common weal was prompted by the spirit of hostility, or at the very least, discrimination that finds no support in reason. It suffices then that the laws operate equally and uniformly on all persons under similar circumstances or that all persons must be treated in the same manner, the conditions not being different, both in the privileges conferred and the liabilities imposed. Favoritism and undue preference cannot be allowed. For the principle is that equal protection and security shall be given to every person under circumstances, which if not identical are analogous. If law be looked upon in terms of burden or charges, those that fall within a class should be treated in the same fashion, whatever restrictions cast on some in the group equally binding on the rest.