G.R. No. L-23645 October 29, 1968
BENJAMIN P. GOMEZ, petitioner-appellee, vs. ENRICO PALOMAR, in his capacity as Postmaster General, HON. BRIGIDO R. VALENCIA, in his capacity as Secretary of Public Works and Communications, and DOMINGO GOPEZ, in his capacity as Acting Postmaster of San Fernando, Pampanga, respondent-appellants.

FACTS

Republic Act 1635, as amended by Republic Act 2631, was enacted to raise funds for the Philippine Tuberculosis Society. It required the Director of Posts to issue semi-postal stamps from August 19 to September 30 each year, with a face value showing the regular postage plus an additional five centavos. During this period, no mail matter would be accepted unless it bore such stamps, except newspapers. The Postmaster General issued implementing administrative orders. On September 15, 1963, petitioner Benjamin P. Gomez mailed a letter at the San Fernando, Pampanga post office. The letter, addressed to Agustin Aquino in Manila, did not bear the required semi-postal stamp and was returned to him. Gomez filed an action for declaratory relief in the Court of First Instance of Pampanga, challenging the constitutionality of the statute and the administrative orders, contending they violated the equal protection clause and the rule of uniformity and equality of taxation. The lower court declared the statute and orders unconstitutional, prompting this appeal by the respondent postal authorities.

ISSUE

The primary issue is whether Republic Act 1635, as amended, and its implementing administrative orders, are unconstitutional for violating the equal protection clause of the Constitution and the rule of uniformity and equality of taxation.

RULING

The Supreme Court reversed the judgment of the lower court. The statute and orders are constitutional.
1. On the Propriety of Declaratory Relief: The Court held that while the mailing of the letter without the stamp constituted a breach before filing, the suit was correctly treated as one for declaratory relief because it sought a ruling not only for that specific letter but also for future mailings by Gomez and other mailers, making him an interested party.
2. On the Equal Protection Clause: The Court ruled that the law does not violate equal protection. The classification of mail users as a class to bear the additional charge is based on a substantial distinction (use of postal services during a specific period) and is germane to the law’s purpose of raising funds for tuberculosis eradication. The exemption for newspapers is reasonable, as they operate under a different postage rate structure and are considered instruments of public information. The administrative exemption for government agencies performing governmental functions is also a valid classification.
3. On Uniformity and Equality of Taxation: The requirement is a regulatory measure primarily for public health, not a pure revenue tax. Even if viewed as a tax, it is uniform because it applies to all persons under the same conditions (i.e., all who use the mails during the specified period). The exceptions granted are based on reasonable classifications.
4. On Non-delegation of Legislative Power: The Court found no undue delegation. The law is complete in itself, setting the policy and standards (raising funds for anti-TB work). The Postmaster General’s role is limited to implementing ministerial details like printing and issuing the stamps.
The law was upheld as a valid exercise of police power for public health, and the implementing orders were deemed consistent with the statute.