GR L 2857; (February, 1950) (Digest)
G.R. No. L-2857; February 28, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MORO ISNAIN, defendant-appellant.
FACTS
The appellant, Moro Isnain, was caught with two others stealing coconuts from a plantation in Zamboanga City. He initially confessed, pleaded guilty before the justice of the peace, and asked for pardon. In the Court of First Instance, he changed his plea but admitted to drinking coconut water from the stolen fruits. The stolen coconuts were valued at over ₱33.
ISSUE
Whether Article 310 of the Revised Penal Code, which imposes a heavier penalty for the theft of coconuts (qualified theft), is unconstitutional for denying equal protection of the laws by not punishing the theft of other agricultural products (e.g., rice and sugar) with the same severity.
RULING
No, the law is constitutional. The equal protection clause does not forbid reasonable classification. The classification for the theft of coconuts is based on a reasonable and substantive distinction: to specially protect and encourage the coconut industry as a vital part of the national economy. The Court noted that coconut groves are more difficult to guard compared to rice or sugarcane fields due to the nature of the trees, making them a frequent target for theft. The law, therefore, has a valid police power objective. The penalty imposed under Article 309(5) in relation to Article 310 of the Revised Penal Code, as amended, was affirmed, applying the Indeterminate Sentence Law.
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