It means that all persons subjected to such legislation shall be treated alike, under

like circumstances and conditions, both in the privileges conferred and in the
liabilities imposed

Equal protection" does not require equal rates of taxation on different classes of
property, nor prohibit unequal taxation so long as the inequality is not based
upon arbitrary classification. Legislation which, in carrying out a public purpose, is
limited in its application, does not violate the provisions if, within the sphere of its
operation, it affects alike all persons similarly situated. It does not prohibit special
legislation or legislation that is limited either in the objects to which it is directed,
or by the territory within which it is to operate. It merely requires that all persons
subjected to such legislation shall be treated alike, under like circumstances and
conditions, both in the privileges conferred and in the liabilities imposed*
Requisites for a valid classification [PEGS]

1. Apply both to present and future conditions

2. Apply equally to all members of the same class
3. Must be germane to the purposes of the law
4. Must be based on substantial distinction

It starts with a sugar central with mill having an annual output capacity of not less than 50,000 piculs of
centri-fugal sugar, in which case an annual municipal license tax of P1,000.00 is provided. Depending
upon the annual output capacity the schedule of taxes continues with P2, 000.00 progressively upward
in twelve other grades until an output capacity of 1,500,001 piculs or more shall have been reached. For
this, the annual tax is P40, 000.00. The tax on sugar refineries is likewise calibrated with similar rates,
starts with P1,000.00 for a refinery with mill having an annual' output capacity of not less than 25,000
bags of 100 lbs. of refined sugar. Then, it continues with the second bracket of from 25,001 bags to
75,000 bags of 100 lbs. Here, the municipal license tax is P1,500.00. Then follow the other rates in the
graduated scale with the ceiling placed at a capacity of 1,750,001 bags or more. The annual municipal
license tax for the last mentioned output capacity is P40,000.00.

Still, the classification, to be reasonable, should be in terms applicable to future conditions as well.
The taxing ordinance should not be singular and exclusive as to exclude any substantially
established sugar central, of the same class as plaintiff, from the coverage of the tax.
Victorias Milling Co. Inc vs The municipality of Victorias Province of Negros
Occidental

Facts:

Ordinance 1 was approved by the municipal Council of Victorias on September 22, 1956 by way
of an amendment to two municipal ordinances separately imposing license taxes on operators
of sugar centrals and sugar refineries. The changes were: with respect to sugar centrals, by
increasing the rates of license taxes; and as to sugar refineries, by increasing the rates of
license taxes as well as the range of graduated schedule of annual output capacity.

Plaintiff Victorias Milling Co. filed a suit to ask for judgment declaring the said Ordinance null
and void as it is discriminatory since it singles out plaintiff which is the only operator of a sugar
central and a sugar refinery within the jurisdiction of defendant municipality ;

1) Whether Ordinance 1 is discriminatory.

RULING:
1) No. The ordinance does not single out Victorias as the only object of the
ordinance. Said ordinance is made to apply to any sugar central or sugar
refinery which may happen to operate in the municipality. The fact that
plaintiff is actually the sole operator of a sugar central and a sugar refinery
does not make the ordinance discriminatory. Not even the name of plaintiff
herein was ever mentioned in the ordinance now disputed.
The ordinance is unlike that in Ormoc Sugar Company vs. Municipal Board of
it is not discriminatory
Ormoc City, which specifically spelled out Ormoc Sugar as the subject of the because the ordinance
here actually covers all
taxation, the name of the company herein was never mentioned in the ordinance. persons who may
Such ordinance here, applicable to future conditions as well. engage in such
business be subjected
to such ordinance and
shall be treated alike,
It does not prohibit special legislation or legislation that is limited either in the under like
objects to which it is directed, or by the territory within which it is to operate. It circumstances and
conditions, both in the
merely requires that all persons subjected to such legislation shall be treated privileges conferred
and in the liabilities
alike, under like circumstances and conditions, both in the privileges conferred imposed by the
municipalities.
and in the liabilities imposed*

The SC, accordingly, rule that Ordinance No. 1, series of 1956, of the Municipality
of Victorias, was promulgated not in the exercise of the municipality's regulatory
power but as a revenue measure tax on occupation or business. The authority to
impose such tax is backed by the express grant of power in Section 1 of C.A. No.
472.