Draft Case Digest V

Equal Protection Clause definition:

Equal protection of the laws is the requirement that all persons or things similarly situated should
be treated alike, both as to rights conferred and responsibilities imposed. It also refers that law be
enforced and applied equally
Valid Classification
The valid classifications as an exception to the equal protection clause are:
1. It must be based upon substantial distinction.
2. It must be germane to the purposes of the law.
3. It must not be limited to existing conditions only.
4. It must apply equally to all members of the class.

People of the Philippines v. Jose O. Vera, G.R. No. L-45685

Facts:
Petitioners herein questions the constitutionality of Act No. 4221 which define the manner of
probation. This case involves the private respondent Mariano Cu Unjien was convicted of
criminal charge by the trial court. While a new trial is ongoing, the petitioner applies for
probation, it was denied at first but later approved. Petitioners claims that the respondent judge
erred has no power to place the private respondent under probation since Act No. 4221 is
inconsistent with the constitution and even if valid, doesn’t give power to the respondent judge.
Issue:
Whether or not, Act No. 4221 is unconstitutional for being violative of the equal protection
clause.
Ruling:
Yes, it is unconstitutional. The act assailed enable one province to defray the salary of a
probation officer while another may refuse or fail to do. As such, person might experience
benefit while others of similar circumstances might not. This is obnoxious discrimination.
Further, the court state that it is clear that the assailed provision creates a situation in which
discrimination and inequality are permitted or allowed. This permits of the denial of the equal
protection of the law and is on that account bad.

Victoriano v. Elizalde Roper Workers’ Union, G.R. No. L-25246

Facts:
Respondent Elizalde Rope Worker’s Union assails the constitutionality of Republic Act No.
3350. In this case, petitioner acted upon his resignation from the respondent union; in response
the union requested his dismissal from the company which was upheld by the company. In the
Court of First Instance, the decision ruled in favor of the petitioner, prohibiting his removal on
grounds of resignation from the Union. In this case, the respondent Union, among its other
claims, argues that the R.A. No. 3350 violates the equal protection clause since by exempting
members of religious sect from the Union, it has granted undue advantages over their fellow
workers.
Issue:
Whether or not, R.A. No. 3350 violates the equal protection clause?
Ruling:
No, it doesn’t violate the equal protection clause. The equal protection of the allows
classification. However, valid classification requires substantial distinction which makes real
differences, being germane to the purpose of the law, not limited to existing conditions, and must
apply equality to members of the same class. This court believe that the assailed law satisfied all
these elements. Ruling otherwise would have constitute inequality against the petitioner.

Ceniza v. COMELEC, G.R. No. L-52304

Facts:
Petitioners challenges the validity of Republic Act No. 5519 which prescribed the classification
of cities based on the annual income. The RA state the those not less than 40 million pesos are to
be classified as highly urbanized cities, except for Baguio because of its status as the summer
capital. Being a highly urbanized city due to its income, Cebu City was not allowed to partake in
election of provincial officials. Mandaue City, while a component city, is likewise not allowed to
partake in provincial election because of its charter. Petitioner claims that such exclusion is
unconstitutional since classifications made are not based on substantial, and as such violates the
equal protection clause.
Issue:
Whether or not, the assailed statutes violate the equal protection clause?
Ruling:
No, it doesn’t violate the equal protection clause. The classification, in this case, is based upon
substantial distinction. Basing city classification through income is valid for it shows the
independence of the city; that is, unlike highly urbanized, smaller income cities needing the
support of the province thus rationalize their inclusion to provincial election. In case of Mandaue
City, it is by legislative discretion to grant certain provision in charter to some and not to others.
Rufino Nunez v. Sandiganbayan, G.R. Nos. L-50581-50617
Facts:
Petitioner Nunez assails the validity of the P.D. No. 1486 creating the Sandiganbayan. Among
his claims, he argues that the P.D. is violative of the equal protection. Specifically, that appeal
became a mere matter of discretion, limited to question of law, and there is only one chance of
appeal. It is, as he claims, different to all other estafa in the manner of appeal.
Issue:
Whether or not, P.D. No. 1486 violates the equal protection clause?
Ruling:
No, it is not necessary offensive to the equal protection clause. Substantial distinction requires
that it makes real differences, germane to the purpose of the law, not limited to existing
conditions, and apply equally to same class. The Constitution specifically makes mention of the
creation Sandiganbayan and recognizes its urgency in solving the problem of dishonesty in
public service. As such, since the enactment of the Constitution, the petitioner ought to have
been aware that different procedure for accused herein doesn’t violate the equal protection
clause. Moreover, the court recognize that equal protection clause must give way to specific
provisions reserving to Filipino citizens of the operation of law.

Philippine Association of Service Exporters, Inc. v. Franklin Drilon, G.R. No. 81958
Facts:
Petitioner Philippine Association of Service Exporters (PASEI) assails the Department Order No.
1, Series of 1988, of the Department of Labor and Employment since it is a discrimination
against males and females. They claim that the said Order does not apply to all Filipino workers
but only to domestic helpers and females with similar skills, as such it violates the equal
protection clause.
Issue:
Whether or not, Department Order No. 1, Series of 1998 violates the equal protection clause?
Ruling:
No, it doesn’t violate the equal protection clause since it is based on substantial distinction. The
court recognize the unhappy plight that has befallen the country’s female labor force abroad; this
is supported by evidences of abuses abroad. The same cannot be made towards the male workers.
There is not enough evidence which requires such interference. As such, discrimination herein is
justified. Similarly, it cannot be said that the Order is invalid for not being applied to all Filipina
workers for such measure would be unreasonable and arbitrary. Not all of them are similarly
circumstanced.
International School Alliance of Educators v. Leonardo Quisumbing, G.R. No. 128845
Facts:
Petitioner International School Alliance assails the decision of the Acting Secretary of Labor
which allows the difference between benefits and salaries between foreign-hires and local-hires
in the International School, Inc. The respondent School, pursuant to P.D. 732, hires both local
and foreign teachers. However, there is difference in benefits and salaries between local and
foreign teachers. When the distinction was questioned in the Department of Labor and
Employment, the Acting secretary ruled in favor of the respondent school, ruling that distinction
do exist.
Issue:
Whether or not, the distinction between local hires and foreign-hires is a valid distinction
justifying difference is salary rates.
Ruling:
No, it is not valid distinction. The measures of different wages herein violate the legal truism of
“equal pay for equal work.” Persons who work with substantial equal qualifications, skill, effort
and responsibility, under similar conditions, should be paid similar salaries; notwithstanding any
“international character.” It is by logic that those that is place in the same position and rank
perform equal work. In this case, there is no reasonable distinction between work done by
foreign-hires and local hires which justify differences in salary wages.

Francisco Tatad v. Lagman, G.R. No. 124360

Facts:
This case assails the validity of Republic Act No. 8180 and Executive Order No. 372 which
prescribed the manner of deregulation of the downstream oil industry. In line with the
government thrust for privatization, the Congress enacted R.A. No. 8180 which among its
content on deregulation puts tariffs of 3 percent for imported crude oil and 7 percent for refined
oil. E.O. 372 was contested also as its calls for the full deregulation. The petitioners claimed that
the act violates the equal protection clause for it discriminates against investors as they don’t
have refineries domestically and would have imported refined petroleum products which I
subject to the tariffs.
Issue:
Whether or not, R.A. No. 8180 and E.O. 372 violates the equal protection clause?
Ruling:
Yes, the R.A. No. 8180 and E.O. 372 is disadvantageous in terms of tariffs imposed. The tariffs
imposed burdens the new players from effectively competing with established oil companies in
the country. They would have to increase their price to be profitable, and as such, would prove
disadvantageous for them. Further, the assailed law would run counter to its purpose, it would
not induce new players in building refineries, rather it will burden them with heavy disincentives.

People v. Cayat, G.R. No. L-45987

Facts:
Respondent Cayat appealed for the decision of the trial court which found him guilty in violation
of Act No. 1639. The act assailed include provision which make it unlawful for non-Christian
tribe from possessing intoxicating liquors which is not accustomed to his tribe. Cuyat, a member
of the non-Christian tribes, acquired a bottle of gin which is not a native liquor, as such he was
convicted. Cuyat then challenges such law for being against the equal protection clause since it
discriminates non-Christian tribes.
Issue:
Whether or not, Act No. 1639 violates the equal protection clause?
Ruling:
No, it doesn’t violate the equal protection clause. The law satisfied the elements of a valid
classification. There is a substantial difference since it is anchored on the peculiarities of non-
Christian tribes. Further, the law intends to protect the non-Christian tribes from the influence of
liquor to whom they are not accustomed. The law is not permanent rather it recognizes the slow
process of civilization of people, and protect them from its negative effects.

Ormoc Sugar Company v. Treasurer of Ormoc City, G.R. No. L-23794

Facts:
Petitioner challenges the validity of Ordinance No. 4, Series of 1964. The Ordinance imposed
one percent tax for sugar milled in the Ormoc Sugar Company, Inc. which will be exported.
Among its claims, petitioner argues that it violates the equal protection clause by imposing tax
on sugar milled in the petitioner’s mill.
Issue:
Whether or not, Ordinance No. 4, Series of 1964 violates the equal protection clause?
Ruling:
Yes, it violates the equal protection clause and as such, unconstitutional. For valid qualification
to prosper, there must be substantial distinction that makes real difference, be germane to the
purpose of the law, classification that applies to the future, and classifications that applies
equally to the same class. These elements were not met since it exclusively taxes the petitioner. It
would, thus, prevent imposition of the same tax to future sugar central and as such, would not be
reasonable in the future.

Biraogo v. Philippine Truth Commission of 2010, G.R. No. 192935

Facts:
In line with his slogan and objective, President Aquino created the Philippine Truth Commission
through signing the Executive Order No. 1. This commission is charged with gathering,
collecting, and assessing evidence of graft and corruption and make recommendations.
Petitioners herein wishes for the EO to be unconstitutional. One of its contentions claims that the
Commission created violates the equal protection clause as it selectively targets officials and
personnel from the previous administration.
Issue:
Whether or not, Executive Order No. 1 violates the equal protection clause?
Ruling:
Yes, it suffers from arbitrary classification. Equal protection clause requires valid classification.
The EO herein purposely and intentionally targets the officials from the previous Arroyo
administration. As such, it is not a valid classification for it discriminates persons of similar
circumstances. For it to be valid and true to its purpose, it should have included past
administration other than the previous Arroyo administration.