G.R. No. L-45987; May 5, 1939
People of the Philippines vs. Cayat

FACTS

Cayat, a native of Baguio and a member of a non-Christian tribe, was prosecuted for violating Sections 2 and 3 of Act No. 1639 . The information alleged that he willfully and unlawfully had in his possession one bottle of A-1-1 gin, an intoxicating liquor other than the native wines and liquors which members of such tribes were accustomed to make prior to the Act. After his demurrer was overruled, Cayat admitted the facts but pleaded not guilty, challenging the constitutionality of Act No. 1639 . The trial court found him guilty and sentenced him to pay a fine. Cayat appealed, arguing the Act was unconstitutional for being discriminatory, a violation of due process, and an improper exercise of police power.

ISSUE

Whether Act No. 1639 is unconstitutional for (1) denying equal protection of the laws, (2) violating due process, and (3) being an improper exercise of police power.

RULING

The Supreme Court affirmed the judgment, upholding the constitutionality of Act No. 1639 .

1. Equal Protection Challenge: The law does not violate the equal protection clause. The classification between members of non-Christian tribes and others is based on substantial distinctions—specifically, the degree of civilization and culture, not on religion or accident of birth. This classification is germane to the law’s purpose of addressing the peculiar conditions within non-Christian tribes to promote their moral and intellectual growth and eventual unification with the Christian population. The classification is reasonable and applies equally to all members of the class.

2. Due Process and Police Power: The Act is a valid exercise of the state’s police power. The state has a long-standing policy, from the Spanish era to the present, to civilize and integrate non-Christian tribes. The prohibition on possessing intoxicating liquors is a measure designed to secure peace and order, remove obstacles to their advancement, and hasten their unification with the rest of the nation. The law is a legitimate means to achieve a public welfare objective. Any incidental inconvenience to educated members of the tribes must yield to the paramount public interest.

The Court emphasized that the wisdom or adequacy of the law is a legislative prerogative. As long as the legislature had the power to enact it, which it did, the Court cannot invalidate it based on policy considerations. The law is constitutional.