People of the Philippines vs Cayat

on November 6, 2010
Equal Protection Requisites of a Valid Classification Bar from Drinking Gin
In 1937, there exists a law (Act 1639) which bars native non-Christians from drinking gin or any other
liquor outside of their customary alcoholic drinks. Cayat, a native of the Cordillera, was caught with an A-
1-1 gin in violation of this Act. He was then charged and sentenced to pay P5.00 and to be imprisoned in
case of insolvency. Cayat admitted his guilt but he challenged the constitutionality of the said Act. He
averred, among others, that it violated his right to equal protection afforded by the constitution. He said
this an attempt to treat them with discrimination or mark them as inferior or less capable race and less
entitled will meet with their instant challenge. The law sought to distinguish and classify native non-
Christians from Christians.
ISSUE: Whether or not the said Act violates the equal protection clause.
HELD: The SC ruled that Act 1639 is valid for it met the requisites of a reasonable classification. The SC
emphasized that it is not enough that the members of a group have the characteristics that distinguish
them from others. The classification must, as an indispensable requisite, not be arbitrary. The requisites
to be complied with are;
(1) must rest on substantial distinctions;
(2) must be germane to the purposes of the law;
(3) must not be limited to existing conditions only; and
(4) must apply equally to all members of the same class.
Act No. 1639 satisfies these requirements. The classification rests on real or substantial, not merely
imaginary or whimsical, distinctions. It is not based upon accident of birth or parentage. The law, then,
does not seek to mark the non-Christian tribes as an inferior or less capable race. On the contrary, all
measures thus far adopted in the promotion of the public policy towards them rest upon a recognition of
their inherent right to equality in the enjoyment of those privileges now enjoyed by their Christian
brothers. But as there can be no true equality before the law, if there is, in fact, no equality in education,
the government has endeavored, by appropriate measures, to raise their culture and civilization and
secure for them the benefits of their progress, with the ultimate end in view of placing them with their
Christian brothers on the basis of true equality.