BROWN v.

Board of Education
1954
FACTS

The cases herein involve the plight of the minors of the Negro race
Through their counsel, they submit their prayer of admission to the public schools of their
community on a non-segregated basis
The information alleges that these minors have been denied admission to schools attended by
white children under laws requiring or allowing segregation accdg. to race
They submit that such practice deprives them of the equal protection of the laws under the 14 th
amendment
They argue that the separate but equal doctrine (equality of treatment is accorded when the
races are provided substantially equal facilities, even though these facilities be separate)
established by the case of Plessy do not apply to their situation as for them, segregated public
schools are not equal and cannot be made equal, and that hence, they are deprived of the equal
protection of the laws

ISSUE

W/N THE segregation of children in public schools solely on the basis of race, even though the
physical facilities and other tangible factors may be equal, deprive the children of the minority
group of equal educational opportunities?
YES

RATIO DECEDENDI

The Court in applying their rulings in certain cases that are quite similar to the case herein opined
that intangible considerations should also be given weight when answering issues like the one
involved in the instant case
The Court argued that to separate them from others of similar age basing solely on race
generates a feeling of inferiority as to their status in the community that may affect their hearts
and minds in a way unlikely ever to be undone
- Segregation of white and colored children in public schools has a detrimental effect on the
African-American children
- Such impact is perceived to be greater when its enforced by law, for the policy of separating
the races is usually interpreted as denoting the inferiority of the minority group; this affects
the childs motivation to learn; as such, this has the tendency to retard the educational and
mental development of the African-American children and to deprive them of some of the
benefits they would receive in a racially integrated school system
The Court further stated that the doctrine of separate but equal has no place in the field of public
education
- Separate school facilities are inherently unequal
RULING: CASES RESTORED TO THE DOCKET; PARTIES ARE REQUESTED TO PRESENT
FURTHER ARGUMENT

1955
The judgments below (Kansas, South Carolina, and Virginia cases), except that, in the Delaware case, are
accordingly reversed, and the cases are remanded to the District Courts to take such proceedings and enter
such orders and decrees consistent with this opinion as are necessary and proper to admit to public
schools on a racially nondiscriminatory basis with all deliberate speed the parties to these cases. The
judgment in the Delaware case -- ordering the immediate admission of the plaintiffs to schools previously
attended only by white children -- is affirmed on the basis of the principles stated in our May 17, 1954,
opinion, but the case is remanded to the Supreme Court of Delaware for such further proceedings as that
Court may deem necessary in light of this opinion.

Tecson v. COMELEC
FACTS

This petition assails the COMELECS dismissal of SPA No. 04-003 (case of the cancellation of
FPJS COC)
Petitioner prays for the disqualification of Ronald Allan Kelley Poe, aka Fernando Poe, Jr., in the
presidential race; that COMELEC cancels his COC on account of material misrepresentation
- Petitioner alleges that Poe is not a natural-born Filipino, and thus, is not qualified to run for
president
- Petitioner argues that neither of Poes parents were Filipino; his father, petitioner contends
was Spanish, while his mother was American; assuming arguendo that Poes father was
Filipino, he could not have transmitted his citizenship to FPJ, as the latter was an illegitimate
child
- Petitioner submitted several documents to support his claims
- Private respondent, on his part, also submitted documentary evidence

RULING + DISCUSSION
(1) The Court, in the exercise of its power of judicial review, possesses jurisdiction over the petition
in G. R. No. 161824, filed under Rule 64, in relation to Rule 65, of the Revised Rules of Civil
Procedure. G.R. No. 161824 assails the resolution of the COMELEC for alleged grave abuse of discretion
in dismissing, for lack of merit, the petition in SPA No. 04-003 which has prayed for the disqualification
of respondent FPJ from running for the position of President in the 10 th May 2004 national elections on
the contention that FPJ has committed material representation in his certificate of candidacy by
representing himself to be a natural-born citizen of the Philippines.
(2) The Court must dismiss, for lack of jurisdiction and prematurity, the petitions in G. R. No.
161434 and No. 161634 both having been directly elevated to this Court in the latters capacity as the
only tribunal to resolve a presidential and vice-presidential election contest under the
Constitution. Evidently, the primary jurisdiction of the Court can directly be invoked only after, not
before, the elections are held.
(3) In ascertaining, in G.R. No. 161824, whether grave abuse of discretion has been committed by
the COMELEC, it is necessary to take on the matter of whether or not respondent FPJ is a natural-born
citizen, which, in turn, depended on whether or not the father of respondent, Allan F. Poe, would have
himself been a Filipino citizen and, in the affirmative, whether or not the alleged illegitimacy of

respondent prevents him from taking after the Filipino citizenship of his putative father. Any conclusion
on the Filipino citizenship of Lorenzo Pou could only be drawn from the presumption that having died in
1954 at 84 years old, Lorenzo would have been born sometime in the year 1870, when the Philippines
was under Spanish rule, and that San Carlos, Pangasinan, his place of residence upon his death in 1954, in
the absence of any other evidence, could have well been his place of residence before death, such that
Lorenzo Pou would have benefited from the en masseFilipinization that the Philippine Bill had effected in
1902. That citizenship (of Lorenzo Pou), if acquired, would thereby extend to his son, Allan F. Poe, father
of respondent FPJ. The 1935 Constitution, during which regime respondent FPJ has seen first light,
confers citizenship to all persons whose fathers are Filipino citizens regardless of whether such children
are legitimate or illegitimate.

The Court discussed the constitutional mandate of equal protection when they
discussed the issue of whether or not illegitimacy would be an obstacle for the
transmission of citizenship from the father to the child. To answer this, the Court
quoted Fr. Bernas:
- "Aside from the fact that such a pronouncement would have no textual foundation in the
Constitution, it would also violate the equal protection clause of the Constitution not
once but twice. First, it would make an illegitimate distinction between a legitimate child
and an illegitimate child, and second, it would make an illegitimate distinction between the
illegitimate child of a Filipino father and the illegitimate child of a Filipino mother.
The doctrine on constitutionally allowable distinctions was established long ago by People
vs. Cayat. I would grant that the distinction between legitimate children and illegitimate
children rests on real differences. x x x But real differences alone do not justify invidious
distinction. Real differences may justify distinction for one purpose but not for another
purpose.
x x x What is the relevance of legitimacy or illegitimacy to elective public service? What
possible state interest can there be for disqualifying an illegitimate child from becoming a
public officer. It was not the fault of the child that his parents had illicit liaison. Why
deprive the child of the fullness of political rights for no fault of his own? To disqualify an
illegitimate child from holding an important public office is to punish him for the
indiscretion of his parents. There is neither justice nor rationality in that. And if there is
neither justice nor rationality in the distinction, then the distinction transgresses the equal
protection clause and must be reprobated.

(4) But while the totality of the evidence may not establish conclusively that respondent FPJ is a
natural-born citizen of the Philippines, the evidence on hand still would preponderate in his favor enough
to hold that he cannot be held guilty of having made a material misrepresentation in his certificate of
candidacy in violation of Section 78, in relation to Section 74, of the Omnibus Election Code. Petitioner
has utterly failed to substantiate his case before the Court, notwithstanding the ample opportunity given to
the parties to present their position and evidence, and to prove whether or not there has been material
misrepresentation, which, as so ruled in Romualdez-Marcos vs. COMELEC, must not only be material,
but also deliberate and willful.

PETITIONS ARE DISMISSED, for want of jurisdiction, and for failure to prove the existence of grave
abuse of discretion.

ABAKADA v. Purisima
FACTS

This petition for prohibition seeks to prevent respondents from implementing and enforcing
RA 9335
R 9335S purpose was to optimize the revenue-generation capability and collection of the
BIR and the BOC
The law provides for a system of rewards and sanctions through the creation of the Rewards
and Incentives Fund and Revenue Performance Evaluation Board; applicable to all officials
and employees of the BIR and the BOC with at least 6 months of service
Petitioners invoking their right as taxpayers filed this petition, assailing the aforementioned
laws constitutionality on the grounds that:
- Establishing a system of rewards transforms the BIR and the BOC into mercenaries and
bounty hunters as they will primarily work for the rewards
- Limiting the scope of the system of rewards and incentives to BIR and BOC employees
violates the constitutional guarantee of equal protection
- The law unduly delegates the power to fix revenue targets to the president without
providing sufficient standard for such matter
- That the congressional oversight committee provided for in the law violates the
separation of powers
HOLDING + RATIO (issues are petitioners grounds for assailing the constitutionality of RA 9335)
1. No, the law will not transform BIR and BOC employees into mercenaries and bounty
hunters. The Court opined that such allegation is not only bereft of any factual basis, but its also
purely conjecture.
- laws enacted by Congress enjoys strong presumption of constitutionality; to nullify this, there
must be patent showing of a clear and unequivocal breach of the Constitution
- to invalidate RA 9335 on tis ground would be an affront to the wisdom of the legislative and
executive branches
- A system of incentives for exceeding the set expectations of a public office is not anathema to
the concept of public accountability. In fact, it recognizes and reinforces dedication to duty,
industry, efficiency and loyalty to public service of deserving government personnel.
- In the same vein, employees of the BIR and the BOC may by law be entitled to a reward
when, as a consequence of their zeal in the enforcement of tax and customs laws, they exceed
their revenue targets. In addition, RA 9335 establishes safeguards to ensure that the reward
will not be claimed if it will be either the fruit of "bounty hunting or mercenary activity" or
the product of the irregular performance of official duties
2. No, the law does not violate the constitutional guarantee of equal protection.
- The equal protection clause recognizes a valid classification, that is, a classification that has
a reasonable foundation or rational basis and not arbitrary. With respect to RA 9335, its
expressed public policy is the optimization of the revenue-generation capability and
collection of the BIR and the BOC. Since the subject of the law is the revenue- generation
capability and collection of the BIR and the BOC, the incentives and/or sanctions provided in

the law should logically pertain to the said agencies. Moreover, the law concerns only the
BIR and the BOC because they have the common distinct primary function of generating
revenues for the national government through the collection of taxes, customs duties, fees and
charges.
3. No, the law does not unduly delegate power to fix target revenues to the president.
- the determination of revenue targets does not rest solely on the President as it also undergoes
the scrutiny of the DBCC
4. Yes, the congressional oversight committee created by RA 9335 violates the separation of
powers.
- Although the subject congressional oversight committee was already dissolved, the Court still
proceeded to answer such issue
- congressional oversight is not unconstitutional per se, meaning, it neither necessarily
constitutes an encroachment on the executive power to implement laws nor undermines the
constitutional separation of powers rather, it is integral to the checks and balances inherent in
a democratic system of government
- It may in fact even enhance the separation of powers as it prevents the over-accumulation of
power in the executive branch
- However, administrative regulations enacted by administrative agencies to implement and
interpret the law which they are entrusted to enforce have the force of law and are entitled to
respect. Such rules and regulations partake of the nature of a statute and are just as binding as
if they have been written in the statute itself. As such, they have the force and effect of law
and enjoy the presumption of constitutionality and legality until they are set aside with
finality in an appropriate case by a competent court. Congress, in the guise of assuming the
role of an overseer, may not pass upon their legality by subjecting them to its stamp of
approval without disturbing the calculated balance of powers established by the Constitution.
In exercising discretion to approve or disapprove the IRR based on a determination of
whether or not they conformed with the provisions of RA 9335, Congress arrogated judicial
power unto itself, a power exclusively vested in this Court by the Constitution.
RULING: PETITION PARTIALLY GRANTED; SEC. 12 OF RA 9335 IS DECLARED VOID AND
UNCONSTITUTIONAL