People vs Cayat

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

THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, 
vs.
CAYAT, defendant-appellant

Facts:

Cayat was a native from Baguio, Benguet, Mt. Province who was found guilty of violation of Sections 2 and 3 of Act 1639: It shall be unlawful for any native of the Philippine Islands who is a member of a non-Christian tribe within the meaning of the Act Numbered Thirteen hundred and ninety-seven, 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 themselves to make prior to the passage of this Act, except as provided in section one hereof; and it shall be the duty of any police officer or other duly authorized agent of the Insular or any provincial, municipal or township government to seize and forthwith destroy any such liquors found unlawfully in the possession of any member of a non-Christian tribe.

SEC. 3. Any person violating the provisions of section one or section two of this Act shall, upon conviction thereof, be punishable for each offense by a fine of not exceeding two hundred pesos or by imprisonment for a term not exceeding six months, in the discretion of the court.

Issues:

1.      If  said law is discriminatory and denies EP of laws;

2.      If said law is an improper exercise of the police power of the state.

Held:

1.     Said statute does not deny EP of laws; 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:

a.      must rest on substantial distinctions;

b.      must be germane to the purposes of the law;

c.       must not be limited to existing conditions only; and

d.      must apply equally to all members of the same class.

Act 1639 meets all such requirements. The classification rests on real and substantial, not merely imaginary or whimsical, distinctions. It is not based upon "accident of birth or parentage” but upon the degree of civilization and culture. "The term 'non-Christian tribes' refers, not to religious belief, but to natives of the Philippine Islands of a low grade of civilization, usually living in tribal relationship apart from settled communities.

When the public safety or the public morals require the discontinuance of a certain practice by certain class of persons, the hand of the Legislature cannot be stayed from providing for its discontinuance by any incidental inconvenience which some members of the class may suffer. The private interests of such members must yield to the paramount interests of the nation. 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 that 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 prohibition is germane to the purposes of the law. It is designed to insure peace and order in and among the non- Christian tribes has often resulted in lawlessness and crime thereby hampering the efforts of the government to raise their standards of life and civilization. This law is not limited in its application to conditions existing at the time of the enactment. It is intended to apply for all times as long as those conditions exists. The Act applies equally to all members of the class. 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 operation nor affect the reasonableness of the classification thus established.

2.      Said statute is not an improper exercise of the PPS. Any measure intended to promote the health, peace, morals, education, and good order of the people or to increase the industries of the state, develop its resources and add to its wealth and prosperity is legitimate exercise of police power, unless shown to be whimsical or capricious as to unduly interfere with the rights of an individual. Act 1639 is designed to promote peace and order to non-Christian tribes and to eventually hasten their equalization and unification with the rest of their Christian brothers.