Consti2Digest – People Vs Cayat, 68 Phil 12, GR L-45987, GR 45987, (5 May 1939)

Equal Protection Clause

DOCTRINE: Protection of laws is not violated by a legislation based on reasonable classification. The
classification to be reasonable, (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; (4) must apply equally to all
members of the same class.

Facts:
Respondent Cayat, native of Baguio, Benguet and a member of the non-Christian tribe was found guilty
of violating sections 2 and 3 of Act No. 1639 for possessing an intoxicating liquor (one bottle of gin)
which is not a native wine.

Section 2 of the said act prohibits any native of the Philippines who is a member of the non-Christian
tribe to buy, receive and possess any intoxicating liquor other than their so-called native wines.
Consequently, Section 3 thereof provides for its punishment.

Cayat challenges the constitutionality of Act No. 1639 on the grounds that it is discriminatory and denies
the equal protection of the laws, violative of the due process and it is an improper exercise of police
power.

Issues:
Whether the Act No. 1639 violates the equal protection clause?

Held:
No, the Act No. 1639 is not violative of the equal protection clause.

Equal protection of the laws is not violated by a legislation based on reasonable classifications. The
classification to be reasonable, (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; (4) must apply equally to all
members of the same class.

Act No. 1639 satisfies these requirements:

On the first requisite, the classification rests on real and substantial distinctions. The non-
Christian tribes refer not to the religious belief, but in a way to the geographical and more directly
to the natives of the Philippines of a low grade of civilization.
Second, Act No. 1639 was designed to insure peace and order among the non-Christian tribes.
The experience of the past and the lower court observed that the use of highly intoxicating liquors
by the non-Christian tribes often resulted in lawlessness and crimes, which hamper the efforts of
the Government to raise their standard of life and civilization.
Third, the said act is intended to apply for all times as long as the conditions exist. Legislature
understood that civilization of a people is a slow process and that hand in hand with it must go
measures of protection and security.
Fourth, the act applies equally to all members of same class.

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