Equal Protection of Laws

Villegas v Hiu Chiong Tsai

In equal protection, it is imperative that the classification should be based on real and
substantial differences having a reasonable relation to the subject of the particular legislation.

Ormoc Sugar v Ormoc City

(1) it is based on substantial distinctions which make real differences;
(2) these are germane to the purpose of the law;
(3) the classification applies not only to present conditions but also to future conditions which
are substantially identical to those of the present;
(4) the classification applies only to those who belong to the same class.

Central Bank Association v BSP

Doctrine of relative unconstitutionality - The classification must not only be reasonable, but
must also apply equally to all members of the class. The proviso may be fair on its face and
impartial in appearance but it cannot be grossly discriminatory in its operation, so as practically
to make unjust distinctions between persons who are without differences.

TWO-TIER TEST
1. RATIONAL BASIS TEST
2. STRICT SCRUTINY TEST
a. The limitation on fundamental rights
b. The implication of suspect classes

Ycasuegi v PAL
In the absence of governmental inference, the liberties guaranteed by the Constitution cannot
be invoked.

People v Siton
Offenders of public order laws are punished not for their status, as for being poor or
unemployed, but for conducting themselves under such circumstances as to endanger the
public peace or cause alarm and apprehension in the community.

League of Cities v COMELEC

As for the equal protection clause: (1) there is no substantial distinction between those
municipalities with pending cityhood bills and those that do not have; (2) the pendency of a
cityhood bill limits the exemption to a specific condition that does not apply to future
conditions; (3) and that this exemption is limited only to the 16 municipalities and does not
apply to municipalities with the same circumstances.
People v Jumanan
This case involves a case of marital rape. Jumawan was convicted for two counts of rape
committed against his wife. On appeal, one of his arguments was that since he and the victim
are husband and wife, they have mutual obligation and right to sexual intercourse. Therefore,
the standards for determining lack of consent in rape cases must be adjusted in view of their
relationship, as compared to ordinary rape cases.
 There must be convincing physical evidence of force and intimidation.
o Court said that showing of external injuries is not indispensable – what is
necessary is the lack of consent.

The Court did not give credence to such argument. The Court said that since the law does not
categorize marital rape and non-marital rape, the theory of the appellant cannot stand. It held
that to treat marital and non-marital rape cases differently would infringe on the equal
protection laws. Equal protection of laws requires that similar subjects should not be treated
differently – such that no person shall be denied the same protection of laws enjoyed by
another in like circumstances.

A married woman has the same right to control her own body as does an unmarried woman. As
such there is no reason to apply the law and the evidentiary rules on rape any differently if the
aggressor is the husband of the victim.

Villanueva v JBC
If a law neither burdens a fundamental right nor targets a suspect class, the classification stands
as long as it bears a rational relationship to some legitimate government end.

Ferrer v Bautista
The SC ruled, that the SHT is constitutional, it following the measures on reasonable
classification, and rendered unconstitutional the garbage fee collection, as there should be no
substantial distinction between occupants of a house and lot, a socialized housing project, and
an apartment.

1-UTAK v COMELEC
Superficial differences do not make for a valid classification.