PEOPLE V.

CAYAT (1939) |EQUAL

PROTECTION CLAUSE
February 5, 2017

G.R. No. L-45987, 68 Phil 12, May 5, 1939

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:
1. 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.
2. 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.
3. 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:
1. Whether the Act No. 1639 violates the equal protection clause?
RULING:
 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.
No. The constitutional right to equal protection of the laws is not absolute but is subject to reasonable
classification. To be reasonable, the classification (a) must be based on substantial distinctions which
make for real differences; (b) must be germane to the purpose of the law; (c) must not be limited to
existing conditions only; and (d) must apply equally to each member of the class.