People v Cayat 68 Phil 12 (1939)

J Moran
Facts:
Cayat, a native of Baguio, as prosecuted for violating Act No. 1639 (secs. 2 and 3).
Caught under his control or custody, one bottle of A-1-1 gin, other than the native wines
allowed to him under this law. In the Justice of the peace, he was made to pay 5. In the
CFI , he was made to pay 50 pesos. On appeal to the SC , he alleged the
unconstitutionality of the Act on the following grounds:
(1) That it is discriminatory and denies the equal protection of the laws;
(2) That it is violative of the due process clause of the Constitution: and.
(3) That it is improper exercise of the police power of the state
Issue:
1. Is the law violative of equal protection?
2. Is it violative of due process?
3. Is it an improper exercise of police power?
Held: No, Judgment affirmed with costs against appellant
Ratio:
1. No, Counsel for defense- any attempt to treat them with discrimination or "mark
them as inferior or less capable rate or less entitled" will meet with their instant
challenge.
The Legislature has passed Act No. 1639 undoubtedly to secure for them the
blessings of peace and harmony; to facilitate, and not to mar, their rapid and steady
march to civilization and culture.
It is an established principle of constitutional law that the guaranty of the equal
protection of the laws is not equal protection of the laws is not violated by a
legislation based on reasonable classification. And the classification, to be
reasonable, (1) must rest on substantial distinctions; (2) must be germane to the
purposes of the law; (3) must not be limited to existing conditions only; and (4)
must apply equally to all members of the same class.
Act No. 1639 satisfies these requirements. The classification of these non-Christian
tribes wasnt based upon "accident of birth or parentage," as counsel to the
appellant asserts, but upon the degree of civilization and culture. The Act was
intended to meet the peculiar conditions existing in the non-Christian tribes.

Regarding being germane to the purposes of the law, the prohibition "to buy,
receive, have in his possession, or drink any ardent spirits, ale, beer, wine, or
intoxicating liquors of any kind, other than the so-called native wines and liquors
which the members of such tribes have been accustomed themselves to make prior
to the passage of this Act.," is unquestionably designed to insure peace and order in
and among the non-Christian tribes. The free use of highly intoxicating liquors by
the non-Christian tribes have often resulted in lawlessness and crimes.
Finally, that the Act applies equally to all members of the class
2. No, to constitute due process of law, notice and hearing are not always
necessary. This rule is especially true where much must be left to the discretion of
the administrative officials in applying a law to particular cases.
Due process of law means simply: (1) that there shall be a law prescribed in
harmony with the general powers of the legislative department of the government;
(2) that it shall be reasonable in its operation; (3) that it shall be enforced according
to the regular methods of procedure prescribed; and (4) that it shall be applicable
alike to all citizens of the state or to all of the class. Ex. Property used in violation of
the law may be confiscated.
3. No, Any measure intended to promote the health, peace, morals, education and
good order of the people or to increase the industries of the state, develop its
resources and add to its wealth and prosperity is a valid exercise of the police
power.
The act is for the promotion of peace and order and ultimately to hasten these
peoples unification with their Christian brothers.
But whether conditions have so changed as to warrant a partial or complete
abrogation of the law, is a matter which rests exclusively within the prerogative of
the National Assembly to determine. In the constitutional scheme of our
government, this court can go no farther than to inquire whether the Legislature
had the power to enact the law.