G.R.

No 78742

Association of Small Landowners in the Philippines

VS.

Secretary of Agrarian Reform

Facts:

The Association of Small Landowners in the Philippines, Inc. sought exception from the land distribution
scheme provided for in R.A. 6657. The Association is comprised of landowners of ricelands and
cornlands whose landholdings do not exceed 7 hectares. They invoke that since their landholdings are
less than 7 hectares, they should not be forced to distribute their land to their tenants under R.A. 6657
for they themselves have shown willingness to till their own land. In short, they want to be exempted
from agrarian reform program because they claim to belong to a different class.

Issue:

Whether or not there was a violation of the equal protection clause.

Ruling:

No. The Association had not shown any proof that they belong to a different class exempt from the
agrarian reform program. Under the law, classification has been defined as the grouping of persons or
things similar to each other in certain particulars and different from each other in these same
particulars. To be valid, it must conform to the following requirements: (1) it must be based on
substantial distinctions; (2) it must be germane to the purposes of the law; (3) it must not be limited to
existing conditions only; and (4) it must apply equally to all the members of the class.

Equal protection simply means that all persons or things similarly situated must be treated alike both as
to the rights conferred and the liabilities imposed. The Association have not shown that they belong to a
different class and entitled to a different treatment. The argument that not only landowners but also
owners of other properties must be made to share the burden of implementing land reform must be
rejected. There is a substantial distinction between these two classes of owners that is clearly visible
except to those who will not see. There is no need to elaborate on this matter. In any event, the
Congress is allowed a wide leeway in providing for a valid classification. Its decision is accorded
recognition and respect by the courts of justice except only where its discretion is abused to the
detriment of the Bill of Rights. In the contrary, it appears that Congress is right in classifying small
landowners as part of the agrarian reform program.