People of the Philippines vs Cayat

G.R. No. L-45987 – 68 Phil. 12 – Political Law – Constitutional Law – Equal Protection – Requisites of a Valid Classification – Prohibition from Drinking Gin

In 1937, there existed a law, Act No. 1639 otherwise known as AN ACT TO PROHIBIT THE SALE, GIFT, OR OTHER DISPOSAL OF ANY INTOXICATING LIQUOR, OTHER THAN THE SO-CALLED NATIVE WINES AND LIQUORS, TO ANY MEMBER OF A NON-CHRISTIAN TRIBE WITHIN THE MEANING OF ACT NUMBERED THIRTEEN HUNDRED AND NINETY-SEVEN, AND TO PROHIBIT THE USE OF SUCH LIQUOR BY ANY MEMBER OF SUCH A TRIBE. Cayat, a native of the Cordillera, was caught with an A-1-1 gin in violation of said Act. He was then charged and was eventually sentenced to pay fine with subsidiary imprisonment in case of insolvency. Cayat admitted his guilt but he challenged the constitutionality of the said Act. He averred, among others, that it violated his right to equal protection afforded by the constitution. He argued that the law treats non-Christian tribes with discrimination or “mark them as inferior or less capable race and less entitled”; that the law was an invalid classification between native non-Christians and Christians.

ISSUE: Whether or not the said Act violates the equal protection clause.

HELD: No. The SC ruled that Act 1639 is valid for it met the requisites of a reasonable classification. The SC emphasized that it is not enough that the members of a group have the characteristics that distinguish them from others. The classification must, as an indispensable requisite, not be arbitrary. The requisites to be complied with are;

(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.” The law, then, does not seek to mark the non-Christian tribes as “an inferior or less capable race.” On the contrary, all measures thus far adopted in the promotion of the public policy towards them rest upon a recognition of their inherent right to equality in the enjoyment of those privileges now enjoyed by their Christian brothers. But as there can be no true equality before the law, if there is, in fact, no equality in education, the government has endeavored, by appropriate measures, to raise their culture and civilization and secure for them the benefits of their progress, with the ultimate end in view of placing them with their Christian brothers on the basis of true equality.

The SC also ruled: Act No. 1639 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.

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NOTE: To better understand the context of this case, it is recommended that you read the 1919 case of Rubi vs Provincial Board which explains why such discrimination existed.