Case Digest: People vs. Cayat, G.R. No. L-45987, May 5, 1939

              Equal Protection of the Laws | Constitutional Law


Facts:

Act No. 1639 forbids any Filipino native who belongs to a non-Christian tribe from purchasing, receiving, or possessing alcoholic beverages other than their own indigenous wines.  Respondent Cayat, a native of Baguio, Benguet and a person belonging to a non-Christian tribe, was found guilty of breaking sections 2 and 3 of Act No. 1639 by having a bottle of gin that is not a native wine.


Issue:

WoN Act No. 1639 is unconstitutional on the grounds that it violates due process, is discriminatory, denies all people the same protection under the law, and is an unlawful use of police power.


Held:

NO.

It satisfies the requirements of a valid classification, one of which is that the classification under the law must rest on real or substantial distinctions establishments. In order for a classification to be considered reasonable, it must: (1) be supported by meaningful distinctions; (2) be relevant to the goals of the law; (3) not be restricted to the status quo; and (4) apply equally to all members of the same class.

Distinction is reasonable. The classification between the members of the non-Christian and the members of the Christian tribes is not based upon accident of birth or parentage but upon the degree of civilization and culture. The non-Christian tribes make reference to the inhabitants of the Philippines who have a low level of civilization rather than any particular religious belief or even location. 

Prohibition is germane to the purpose of the law. The government's efforts to improve the non-Christian tribes' standard of living and civilization are hampered by the use of highly intoxicating liquors by these tribes, as the lower court and historical experience both noted.

Law is not limited in its application. The legislature recognized that a people's civilization is a gradual process and that security and protection measures must accompany it. Fourth, all members of the same class are treated equally under the law.

The law apply equally to all members of the same class.


Ratio:

In order for a classification to be considered reasonable, it must: (1) be supported by meaningful distinctions; (2) be relevant to the goals of the law; (3) not be restricted to the status quo; and (4) apply equally to all members of the same class.


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