1/28/24, 12:36 PM Case Digest: G.R. No. 14078 - Rubi v.

Provincial Board of Mindoro

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Title
Rubi v. Provincial Board of Mindoro

Case Ponente Decision Date

G.R. No. 14078 MALCOLM, J : 1919-03-07

In a habeas corpus case, the Philippine Supreme Court upholds the

constitutionality of a provision allowing provincial governors to direct non-
Christian inhabitants to live on designated public lands, citing historical treatment
of indigenous people and the government's authority to promote the general
welfare and public interest.

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Facts:
This case involves an application for habeas corpus in favor of Rubi and other
Manguianes (indigenous people) of the Province of Mindoro. Rubi and his companions
are being held on the reservation established at Tigbao, Mindoro, against their will, and
one Dabalos is being held in the prison at Calapan for running away from the reservation.
The provincial board of Mindoro adopted Resolution No. 25, which authorized the
provincial governor to direct non-Christian inhabitants, including the Manguianes, to live
on designated public lands. The resolution was approved by the Secretary of the Interior.
The provincial governor of Mindoro issued Executive Order No. 2, directing all
Manguianes in the vicinity of Naujan, Pola, Baco River, Dulangan, and Rubi's place in
Calapan to take up their habitation on the site of Tigbao, Naujan Lake, by December 31,
1917. Failure to comply with the order would result in imprisonment for up to sixty days.

Issue:

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1/28/24, 12:36 PM Case Digest: G.R. No. 14078 - Rubi v. Provincial Board of Mindoro

The main issue in this case is whether the confinement of the Manguianes on the
reservation is legal and constitutional.

Ruling:
The Supreme Court ruled that the confinement of the Manguianes on the reservation is
legal and constitutional.

Ratio:
1. The government has a legitimate interest in promoting the welfare and development
of non-Christians, as demonstrated by the different laws enacted for their benefit.
2. The term "non-Christian" refers to natives of the Philippines with a low level of
civilization, not religious belief. It is a classification based on the need to introduce
civilized customs and improve living conditions.
3. The treatment of American Indians as "in a state of pupilage" and the plenary
authority of the United States over them serve as a precedent for the treatment of
non-Christian inhabitants in the Philippines. The government has the authority to
regulate their lives for their own benefit and protection.
4. Section 2145 of the Administrative Code of 1917, which authorizes the provincial
governor to direct non-Christian inhabitants to live on designated public lands, is not
an unlawful delegation of legislative power. It provides sufficient standards and
safeguards to prevent arbitrary exercise of authority.
5. The term "non-Christian" in the law does not discriminate based on religious
differences and is therefore not invalid. It is a classification based on the level of
civilization and does not infringe on the freedom of religion.
6. The authority conferred upon executive officials by Section 2145 does not unduly
interfere with the liberty of the Manguianes considering their low level of civilization.
The government's actions are justified by the need to promote their development and
protect their welfare.
7. Section 2145 does not violate due process of law and equal protection of the laws as it
applies to all individuals in the class of non-Christian inhabitants. The law is
rationally related to a legitimate government interest and treats all individuals in the
class equally.
8. Confinement on the reservation does not constitute slavery and involuntary
servitude. The government's objective is to establish friendly relations with non-
Christians and promote their development and advancement in civilization.
9. The exercise of the police power by the government in promoting the general welfare
and public interest is justified. The government has the authority to regulate the lives

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of non-Christians for their own benefit and protection.

10. The power of the court to overrule the judgment of the legislature should be
exercised cautiously, especially when political ideas are involved. The court should
defer to the wisdom and judgment of the legislature in matters concerning the
welfare and development of non-Christians.
11. Section 2145 of the Administrative Code of 1917 is constitutional. It is a valid exercise
of the police power and is rationally related to a legitimate government interest.

END

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