Louis Biraogo vs The Philippine Truth Commission of 2010
G.R. No. 192935 – 651 Phil. 374 – Political Law – Constitutional Law – Bill of Rights – Equal protection Clause – Valid Classification – Tests in Determining Valid Classification – Rational Basis Test, Strict Scrutiny Test, Intermediate Scrutiny Test
Upon assumption of office, President Benigno Aquino III issued Executive Order No. 1 which created the Philippine Truth Commission. The purpose of the PTC was to investigate alleged graft and corrupt practices during the Arroyo Administration.
ISSUE: Whether or not the EO No. 1 and the PTC violated the equal protection clause.
HELD: Yes. EO No. 1 and the PTC singled out the officials of the Arroyo Administration. The Supreme Court clarified the following:
Tests in determining compliance with the equal protection clause:
| Rational Basis Test | Strict Scrutiny Test | Intermediate Scrutiny Test |
| The guaranty of the equal protection of the laws is not violated by legislation based on reasonable classification. This standard of review is typically quite differential; legislative classifications are presumed to be valid largely for the reason that the drawing of lines that create distinctions is peculiarly a legislative task and unavoidable one. | It is applied when the challenged statute either:
a. Classifies on the basis of an inherently suspect characteristic or In these situations, the usual presumption of constitutionality is reversed, and it falls upon the government to demonstrate that its classification has been narrowly tailored to further compelling governmental interests; otherwise, the law shall be declared unconstitutional for violating the equal protection clause. |
The government must show that the challenged classification serves an important state interest and that the classification is at least substantially related to serving that interest. |
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