International School Alliance of Educators vs.

Quisumbing
G.R. No. 128845, June 1, 2000
Facts:
Described as discrimination, Filipino teachers locally hired of private respondent School receive salaries less than their
counterparts hired abroad. Private respondent International School, Inc., pursuant to Presidential Decree 732, is a
domestic educational institution established primarily for dependents of foreign diplomatic personnel and other temporary
residents. To enable the School to continue carrying out its educational program and improve its standard of instruction
the same decree authorizes the School to employ its own teaching and management personnel selected by it either
locally or abroad, from Philippine or other nationalities. Accordingly, the School hires both foreign and local teachers as
members of its faculty, classifying the same into two: (1) foreign-hires and (2) local-hires. The School grants foreign-hires
certain benefits not accorded local-hires. Foreign-hires are also paid a salary rate twenty-five percent (25%) more than
local-hires. The School justifies the difference on two significant economic disadvantages foreign-hires have to endurethe dislocation factor and limited tenure. Petitioner conducted strike for the failure of the National Conciliation and
Mediation Board to bring the parties to a compromise. The Department of Labor and Employment (DOLE) issued an
Order resolving the parity and representation issues in favor of the School. DOLE contends that the Union cannot invoke
the equal protection clause as it is an established principle of constitutional law that the guarantee of equal protection of
the laws is not violated by legislation or private covenants based on reasonable classification.
Issue:
Whether or not petitioner was denied the equal protection clause of
the 1987 Constitution.
Ruling:
The Constitution, in Article XIII, Section 3 thereof, provides "to give highest priority to the enactment of measures that
protect and enhance the right of all people to human dignity, reduce social, economic, and political inequalities" hence
entitling the labor to "humane conditions of work." These conditions are not restricted to the physical workplace but
include as well the manner by which employers treat their employees. The Constitution also directs the State to promote
"equality of employment opportunities for all." Similarly, the Labor Code provides that the State shall "ensure equal work
opportunities regardless of sex, race or creed." These relations are not merely contractual but are so impressed with
public interest that labor contracts, collective bargaining agreements included, must yield to the common good. Should
such contracts contain stipulations that are contrary to public policy, courts will strike down these stipulations. The
foregoing provisions impregnably institutionalize in this jurisdiction the long honored legal truism of "equal pay for equal
work." Persons who work with substantially equal qualifications, skill, effort and responsibility, under similar conditions,
should be paid similar salaries. This rule applies to the School, its international character notwithstanding. The School
contends that petitioner has not adduced evidence that local-hires perform work equal to that of foreign-hires. The Court
found this argument devoid of merit. If an employer accords employees the same position and rank, the presumption is
that these employees perform equal work. The School cannot invoke the need to entice foreign-hires to leave their
domicile to rationalize the distinction in salary rates without violating the principle of equal work for equal pay. While the
Court the need of the School to attract foreign-hires, salaries should not be used as an enticement to the prejudice of
local-hires. The local-hires perform the same services as foreign-hires and they ought to be paid the same salaries as the
latter. The dislocation factor and limited tenure affecting foreign-hires are adequately compensated by certain benefits
accorded them which are not enjoyed by local-hires, such as housing, transportation, shipping costs, taxes and home
leave travel allowances.
People v. Jalosjos [G.R. Nos. 132875-76. February 3, 2000]
FACTS
The accused-appellant, Romeo G. Jalosjos is a full-fledged member of Congress who is now confined at the national
penitentiary while his conviction for statutory rape on two counts and acts of lasciviousness on six counts is pending
appeal. The accused-appellant filed this motion asking that he be allowed to fully discharge the duties of a Congressman,
including attendance at legislative sessions and committee meetings despite his having been convicted in the first
instance of a non-bailable offense.
ISSUE
Whether or not being a Congressman is a substantial differentiation which removes the accused-appellant as a prisoner
from the same class as all persons validly confined under law by reason of the mandate of the sovereign will.
RULING
NO. While the Constitution guarantees: x x x nor shall any person be denied the equal protection of laws., this simply
means that all persons similarly situated shall be treated alike both in rights enjoyed and responsibilities imposed. The
duties imposed by the mandate of the people are multifarious. The Court cannot validate badges of inequality. The
necessities imposed by public welfare may justify exercise of government authority to regulate even if thereby certain
groups may plausibly assert that their interests are disregarded. Here, election to the position of Congressman is not a
reasonable classification in criminal law enforcement. The functions and duties of the office are not substantial distinctions
which lift him from the class of prisoners interrupted in their freedom and restricted in liberty of movement. Lawful arrest
and confinement are germane to the purposes of the law and apply to all those belonging to the same class. Hence, the
performance of legitimate and even essential duties by public officers has never been an excuse to free a person validly in
prison.

PEOPLE VS. CAYAT

[68 PHIL 12; G.R. NO. 45987; 5 MAY 1939]
Facts: Law prohibits any member of a non-Christian tribe to buy, receive, have in his possession, or drink, any
intoxicating liquors of any kind. The law, Act No. 1639, exempts only the so-called native wines orliquors which the
members of such tribes have been accustomed to take.
Issue: Whether or Not the law denies equal protection to one prosecuted and sentenced for violation of said law.
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.
The 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 term
non-Christian tribes refers to a geographical area and more directly to natives of the Philippines of a low
grade civilization usually living in tribal relationship apart from settled communities. The distinction is reasonable for the
Act was intended to meet the peculiar conditions existing in the non- Christian tribes
The prohibition is germane to the purposes of the law. It is designed to insure peace and order in and among the nonChristian tribes has often resulted in lawlessness and crime thereby hampering the efforts of the government to raise
their standards of life and civilization. This law is not limited in its application to conditions existing at the time of the
enactment. It is intended to apply for all times as long as those conditions exists. The Act applies equally to all members
of the class. That it may be unfair in its operation against a certain number of non- Christians by reason of their degree of
culture is not an argument against the equality of its operation nor affect the reasonableness of the classification thus
established.