GR L 13997; (March, 1919) (Digest)
March 7, 2026GR L 14454; (March, 1919) (Digest)
March 7, 2026G.R. No. L-14078, March 7, 1919
RUBI, ET AL. (Manguianes) vs. THE PROVINCIAL BOARD OF MINDORO
FACTS:
The petitioners, Rubi and other Manguianes (indigenous people of Mindoro), filed an application for a writ of habeas corpus. They alleged they were being illegally deprived of their liberty by provincial officials for refusing to live within a government-established reservation at Tigbao, Lake Naujan, Mindoro. One petitioner, Dabalos, was detained in prison for escaping from the reservation. The provincial government acted under Resolution No. 25 (1917) of the Provincial Board of Mindoro and Executive Order No. 2 issued by the Provincial Governor, which directed specified Manguianes to take up habitation in the Tigbao reservation by December 31, 1917. These actions were based on Section 2145 of the Administrative Code of 1917, which authorized provincial governors, with the approval of the Department Head, to direct non-Christian inhabitants to live on selected public land sites in the interest of law and order. Section 2759 of the same Code imposed a penalty of imprisonment for refusal to comply. The resolution and order were approved by the Secretary of the Interior. The petitioners challenged the constitutionality of these statutory provisions.
ISSUE:
Are Sections 2145 and 2759 of the Administrative Code of 1917, which authorize the compulsory relocation of non-Christian inhabitants to designated reservations, constitutional?
RULING:
Yes, the provisions are constitutional. The Supreme Court denied the petition for habeas corpus. The Court held that the classification of “non-Christians” as a distinct group for special legislation is valid and reasonable, given the state’s duty to protect and civilize indigenous peoples who are not yet integrated into the body politic. The power exercised under Sections 2145 and 2759 is a legitimate exercise of the police power and the state’s prerogative as parens patriae (guardian) over its non-Christian inhabitants. The law is not discriminatory as it applies equally to all in the same class (non-Christians) and is based on a substantial distinction (degree of civilization and integration) relevant to the law’s purpose of promoting order, protection, and advancement. The Court found the measures were for the benefit of the Manguianes themselves and for public welfare, analogous to policies applied to American Indians. The detention of Dabalos for violating the order was therefore legal.
