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THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CAYAT, Defendant-Appellant

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Rejmali Good

(1) Cayat, a native of Baguio, was prosecuted under Act 1639 for possessing intoxicating liquor. He argued the Act was unconstitutional as it denied equal protection and due process by classifying natives as "non-Christian tribes." (2) The Court ruled the classification was reasonable as it referred to geographical area and level of civilization, not religion. It was also germane to the purpose of the law, which was to prevent lawlessness from free liquor use among tribes. (3) The Act was intended to apply long-term as long as the conditions existed, and due process was followed. The Court therefore affirmed the judgment against Cayat.

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THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CAYAT, Defendant-Appellant

Uploaded by

Rejmali Good
63 views2 pages
(1) Cayat, a native of Baguio, was prosecuted under Act 1639 for possessing intoxicating liquor. He argued the Act was unconstitutional as it denied equal protection and due process by classifying natives as "non-Christian tribes." (2) The Court ruled the classification was reasonable as it referred to geographical area and level of civilization, not religion. It was also germane to the purpose of the law, which was to prevent lawlessness from free liquor use among tribes. (3) The Act was intended to apply long-term as long as the conditions existed, and due process was followed. The Court therefore affirmed the judgment against Cayat.

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People v Cayat

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(1) Cayat, a native of Baguio, was prosecuted under Act 1639 for possessing intoxicating liquor. He argued the Act was unconstitutional as it denied equal protection and due process by classifying natives as "non-Christian tribes." (2) The Court ruled the classification was reasonable as it referred to geographical area and level of civilization, not religion. It was also germane to the purpose of the law, which was to prevent lawlessness from free liquor use among tribes. (3) The Act was intended to apply long-term as long as the conditions existed, and due process was followed. The Court therefore affirmed the judgment against Cayat.

Copyright:

© All Rights Reserved
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
63 views2 pages

THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CAYAT, Defendant-Appellant

Uploaded by

Rejmali Good
(1) Cayat, a native of Baguio, was prosecuted under Act 1639 for possessing intoxicating liquor. He argued the Act was unconstitutional as it denied equal protection and due process by classifying natives as "non-Christian tribes." (2) The Court ruled the classification was reasonable as it referred to geographical area and level of civilization, not religion. It was also germane to the purpose of the law, which was to prevent lawlessness from free liquor use among tribes. (3) The Act was intended to apply long-term as long as the conditions existed, and due process was followed. The Court therefore affirmed the judgment against Cayat.

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© All Rights Reserved
Download as DOCX, PDF, TXT or read online from Scribd
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THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CAYAT, defendant-appellant.

(GR # 45987, May 05, 1939)

Facts of the Case:


1) A native of Baguio named Cayat was prosecuted under a crime of Act 1639 Section 2 and 3 for
intoxicating liquor. He was penalized by the Court of First Instance for the said crime. On appeal,
Cayat invokes the unconstitutionality of the said Act that it denies equal protection of laws for
marking them as “non-Christian tribes” and due process clauses.

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, at the discretion of
the court.

Issues:

1) Whether or not Act 1639 violates equal protection clause and due process clause

RULING:

It is an established principle of constitutional law that the guarantee 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;

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 relationships apart from settled communities." (Rubi vs. Provincial Board of Mindoro, supra.) This
distinction is unquestionably reasonable, for 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.

(2) must be germane to the purposes of the law;

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.

(3) must not be limited to existing conditions only


It is intended to apply for all times as long as those conditions exist. The Act was not predicated, as
counsel for appellant asserts, upon the assumption that the non-Christians are "impermeable to any
civilizing influence." On the contrary, 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.

and (4) must apply equally to all members of the same class

The Act applies equally to all members of the class is evident from a perusal thereof. That it may be
unfair in its operation against a certain number non-Christians by reason of their degree of culture, is
not an argument against the equality of its application.

Due process of law means simply: (1) that there shall be a law prescribed in harmony with the general
powers of the legislative department of the government; (2) that it shall be reasonable in its operation;
(3) that it shall be enforced according to the regular methods of procedure prescribed; and (4) that it
shall be applicable alike to all citizens of the state or to all of the class. Thus, a person's property may be
seized by the government in payment of taxes without judicial hearing; or property used in violation of
law may be confiscated or when the property constitutes corpus delicti, as in the instant.

Decision:

Judgment is affirmed, with costs against appellant.

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