Constitutional Law: PEOPLE VS. CAYAT

PEOPLE VS. CAYAT

Facts:
“Law prohibits any member of a non-Christian tribe to buy, receive, have in his possession, or drink, any intoxicating liquors of any kind.” The law, Act No. 1639, exempts only the so-called native wines or liquors which the members of such tribes have been accustomed to take.

Issue: Whether or Not the law denies equal protection to one prosecuted and sentenced for violation of said law.

Held:

No. It satisfies the requirements of a valid classification, one of which is that the classification under the law must rest on real or substantial distinctions. The distinction is reasonable. The classification between the members of the non- Christian and the members of the Christian tribes is not based upon accident of birth or parentage but upon the degree of civilization and culture. The term ‘non-Christian tribes’ refers to a geographical area and more directly to natives of the Philippines of a low grade civilization usually living in tribal relationship apart from settled communities. The distinction is reasonable for the Act was intended to meet the peculiar conditions existing in the non- Christian tribes” The prohibition is germane to the purposes of the law. It is designed to insure peace and order in and among the non- Christian tribes has often resulted in lawlessness and crime thereby hampering the efforts of the government to raise their standards of life and civilization. This law is not limited in its application to conditions existing at the time of the enactment. It is intended to apply for all times as long as those conditions exist. The Act applies equally to all members of the class. That it may be unfair in its operation against a certain number of non- Christians by reason of their degree of culture is not an argument against the equality of its operation nor affect the reasonableness of the classification thus established.
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