Rubi vs Provincial Board Political Law Delegation of Powers Rubi and various other Manguianes in the province of Mindoro

o were ordered by the provincial governor of Mindoro to remove their residence from their native habitat and to established themselves on a reservation at Tigbao in the province of Mindoro and to remain there, or be punished by imprisonment if they escaped. Manguianes had been ordered to live in a reservation made to that end and for purposes of cultivation under certain plans. The Manguianes are a Non-Christian tribe with a very low culture. These reservations, as appears from the resolution of the Provincial oard, e!tends over an area of "## hectares of land, which is appro!imately $### acres, on which about %## Manguianes are confined. &ne of the Manguianes, 'abalos, escaped from the reservation and was ta(en in hand by the provincial sheriff and placed in prison at Calapan, solely because he escaped from the reservation. )n application for habeas corpus was made on behalf of Rubi and other Manguianes of the province, alleging that by virtue of the resolution of the provincial board of Mindoro creating the reservation, they had been illegally deprived of their liberty. *n this case the validity of section $+,- of the )dministrative Code, reading. /0ith the prior approval of the 'epartment 1ead, the provincial governor of any province in which non-Christian inhabitants are found is authori2ed, when such a course is deemed necessary in the interest of law and order, to direct such inhabitants to ta(e up their habitation on sites on unoccupied public lands to be selected by him and approved by the provincial board,3 was challenged. ISSUE: 0hether or not the said law is constitutional. HELD: y a vote of five to four, the 4upreme Court sustained the constitutionality of this section of the )dministrative Code. )mong other things, it was held that the term /non-Christian3 should not be given a literal meaning or a religious signification, but that it was intended to relate to degrees of civili2ation. The term /non-Christian3 it was said, refers not to religious belief, but in a way to geographical area, and more directly to natives of the Philippine *slands of a low grade of civili2ation. &n the other hand, none of the provisions of the Philippine &rganic 5aw could have had the effect of denying to the 6overnment of the Philippine *slands, acting through its 5egislature, the right to e!ercise that most essential, insistent, and illimitable of powers, the sovereign police power, in the promotion of the general welfare and the public interest. when to advance the public welfare, the law was found to be a legitimate e!ertion of the police power, )nd it is unnecessary to add that the prompt registration of titles to land in the Philippines constitutes an advancement of the public interests, for, besides promoting peace and good order among landowners in particular and the people in general, it helps increase the industries of the country, and ma(es for the development of the natural resources, with the conse7uent progress of the general prosperity. )nd these ends are pursued in a special manner by the 4tate through the e!ercise of its police power. The 4upreme Court held that the resolution of the provincial board of Mindoro was neither discriminatory nor class legislation, and stated among other things. /. . . one cannot hold that the liberty of the citi2en is unduly interfered with when the degree of civili2ation of the Manguianes is considered. They are restrained for their own good and the general good of the Philippines. Nor can one say that due process of law has not been followed. To go bac( to our definition of due process of law and e7ual protection of the laws, there e!ists a law8 the law seems to be reasonable8 it is enforced according to the regular methods of procedure prescribed8 and it applies ali(e to all of a class.3

Rubi et al., vs. Provincial Board of Mindoro (G.R. No. L-1407 , 1!1! Marc" 7#

$%&'(: This is a petition for habeas corpus in favor of Rubi and other Manguianes of the Province of Mindoro. It is alleged that the Manguianes are being illegally deprived of their liberty by the provincial officials. )((*+(: Whether or not the petition should be granted. a) Whether or not Section 2 !" of the #d$inistrative %ode of & & is unconstitutional on the ground of invalid delegation of legislative po'er. b) Whether or not Section 2 !" of the #d$inistrative %ode of & & is unconstitutional on the ground of religious discri$ination. c) Whether or not Section 2 !" of the #d$inistrative %ode of & & is unconstitutional on the ground that it denied liberty 'ithout due process of la' and e(ual protection of the la's. d) Whether or not Section 2 !" of the #d$inistrative %ode of & & is unconstitutional on the ground that it constituted slavery and involuntary servitude. e) Whether or not Section 2 !" of the #d$inistrative %ode of & & is a valid e)ercise of police po'er. R*L)NG, The petition for habeas corpus is granted. -+L., a) Section 2 !" of the #d$inistrative %ode of & & is a valid delegation of legislative po'er by the *egislature+ hence constitutional. The *egislature $erely conferred+ upon the provincial governor 'ith the approval of the provincial board and the depart$ent head+ discretionary authority as to its e)ecution+ to be e)ercised under and in pursuance of the la'. b) Since the ter$ ,non-%hristian, is construed to refer to the natives 'ith a lo' grade of civili.ation+ Section 2 !" of the #d$inistrative %ode of & & does not discri$inate bet'een individuals on account of religious differences and is therefore constitutional. c) Section 2 !" of the #d$inistrative %ode of & & does not unduly interfere liberty of the citi.en 'hen the degree of civili.ation of the Manguianes is concerned. They are restrained for their o'n good and the general good the Philippines. /either it violated due process and e(ual protection of the la's since the la' is reasonable0 it is enforced according to the regular $ethods of procedure and it applies to all. d) %onfine$ent in reservations in accordance 'ith the said la' does not constitute slavery and involuntary servitude. 1ence+ constitutional. e) It is a valid e)ercise of police po'er because its purpose is to provide the$ education and to i$prove their health and $orals.