People v. Cayat Digest

People vs.
Cayat
FACTS:
The accused, Cayat, a native of Baguio, Benguet, Mountain Province was sentenced by
the justice of the peace of court of Baguio for violation of Act No. 1639 (secs. 2 and 3)
SEC. 2. It shall be unlawful for any native of the Philippine Islands who is a
member of a non-Christian tribe within the meaning of the Act Numbered
Thirteen hundred and ninety-seven, to buy, receive, have in his possession, or
drink any ardent spirits, ale, beer, wine, or intoxicating liquors of any kind, other
than the so-called native wines and liquors which the members of such tribes
have been accustomed themselves to make prior to the passage of this Act, except
as provided in section one hereof; and it shall be the duty of any police officer or
other duly authorized agent of the Insular or any provincial, municipal or
township government to seize and forthwith destroy any such liquors found
unlawfully in the possession of any member of a non-Christian tribe.
SEC. 3. Any person violating the provisions of section one or section two of this
Act shall, upon conviction thereof, be punishable for each offense by a fine of not
exceeding two hundred pesos or by imprisonment for a term not exceeding six
months, in the discretion of the court.
At the trial, cayat admitted all the facts alleged in the information that on or about the
January 25, 1937, in the City of Baguio, Philippines, and within the jurisdiction of this
court, the accused, Cayat, being a member of the non-Christian tribes, did receive,
acquire, and have in his possession and under his control or custody, one bottle of A gin,
an intoxicating liquor, other than the so-called native wines and liquors which the
members of such tribes have been accustomed themselves to make prior to the passage of
Act No. 1639, but pleaded not guilty to the charge for the reasons adduced in his
demurrer and submitted the case on the pleadings. The trial court found him guilty of the
crime charged and sentenced him,
The case was appealed and the accused challenges the constitutionality of the Act on the
following ground:
(1) That it is discriminatory and denies the equal protection of the laws;
Issue:
Whether or not there is discriminatory and denial of equal protection of the laws
Held:
The Legislature has passed Act No. 1639 undoubtedly to secure for them the blessings of
peace and harmony; to facilitate, and not to mar, their rapid and steady march to
civilization and culture. It is, therefore, in this light that the Act must be understood and
applied.
It is an established principle of constitutional law that the guaranty of the equal

protection of the laws is not equal protection of the laws is not violated by a legislation
based on reasonable classification. And the classification, to be reasonable,
(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 and substantial,
not merely imaginary or whimsical, distinctions. It is not based upon "accident of birth or
parentage, but upon the degree of civilization and culture.
"The term 'non-Christian tribes' refers, not to religious belief, but, in a way, to the
geographical area, and, more directly, to natives of the Philippine Islands of a low grade
of civilization, usually living in tribal relationship apart from settled communities."
The Act was intended to meet the peculiar conditions existing in the non-Christian tribes.
The exceptional cases of certain members thereof who at present have reached a position
of cultural equality with their Christian brothers, cannot affect the reasonableness of the
classification thus established.
That it is germane to the purposes of law cannot be doubted. The prohibition "to buy,
receive, have in his possession, or drink any ardent spirits, ale, beer, wine, or intoxicating
liquors of any kind, other than the so-called native wines and liquors which the members
of such tribes have been accustomed themselves to make prior to the passage of this Act.
It is designed to insure peace and order in and among the non-Christian tribes. It has been
the sad experience of the past, as the observations of the lower court disclose, that the
free use of highly intoxicating liquors by the non-Christian tribes have often resulted in
lawlessness and crimes, thereby hampering the efforts of the government to raise their
standard of life and civilization.
The law is not limited in its application to conditions existing at the time of its enactment.
It is intended to apply for all times as long as those conditions exist
The Legislature understood that the civilization of a people is a slow process and that
hand in hand with it must go measures of protection and security.

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People vs.

It is an established principle of constitutional law that the guaranty of the equal

(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.

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