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People V Cayat

1. Cayat challenged the constitutionality of an act that prohibited members of non-Christian tribes from possessing alcohol, claiming it violated equal protection. 2. The court upheld the act, finding the classification was based on real distinctions related to civilization levels and reducing lawlessness, not religion or beliefs. 3. Cayat also claimed a due process violation, but the court found the act was properly within the police power of the government to promote order and development in the tribes.

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197 views2 pages

People V Cayat

1. Cayat challenged the constitutionality of an act that prohibited members of non-Christian tribes from possessing alcohol, claiming it violated equal protection. 2. The court upheld the act, finding the classification was based on real distinctions related to civilization levels and reducing lawlessness, not religion or beliefs. 3. Cayat also claimed a due process violation, but the court found the act was properly within the police power of the government to promote order and development in the tribes.

Uploaded by

delayinggratification
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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People v.

Cayat
Topic: Equal Protection clause

Parties:
 Petitioner: People of the PH
 Respondent: Cayat
 
Facts:
 Cayat, a native of Baguio, Benguet was sentenced by the justice of the peace of the
court of Baguio to pay a fine of P5 or suffer subsidiary imprisonment in case of
insolvency for violating Act No. 1639 (which prohibits any native of the PH who is a
member of a non-Christian tribe to buy, receive, have in his possession or drink any
ardent spirits, ale, beer, wine, etc.)
 Cayat was found to willfully, unlawfully and illegally have in his possession and
under his control or custody, 1 bottle of A1-1 gin
 Cayat challenges the constitutionality of the Act on the following grounds:

1. It is discriminatory and denies the equal protection of the


laws;
2. That it is violative of the due process clause of the
Constitution
3. That it is an improper exercise of police power
 
RULING/RATIONALE
 
I. EQUAL PROTECTION
1. The classification rests on real or substantial, not merely imaginary or whimsical
distinctions.
a. The term “non-Christian tribes refers to the geographical area, not religion or
belief and more directly to the natives of the Philippines of low grade of
civilization living in tribal relationships. This distinction is unquestionably
reasonable for the ac was intended to meet the peculiar conditions existing in the
Non-Christian tribes.
2. The distinction is germane to the purposes of the law.
a. It has been the sad experience of the past 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 gov’t to raise their standard of
live and civilization.
2. The 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.
a. The legislature understood that the civilization of a people is a slow process.
2. The Act applies equally to all members of the class.
 
II. DUE PROCESS
1. Petitioners argue that the law violates due process insofar as it authorizes agents of the
gov’t to seize and forthwith destroy any prohibited liquors found unlawfully in the
possession of the non-Christian tribes. But the case is not concerned about that
provision.
2. Requisites of due process:
a. That there shall be a law prescribed n harmony with the general powers of the
legislative department of the government;
b. That it shall be reasonable in its operation;
c. That it shall be enforced according to the regular methods of procedure
prescribed;
d. That it shall be applicable alike to all citizens of the state or to all of a class.
2. Thus, a person’s property may be seized by the gov’t 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 case.
 
III. POLICE POWER
1. The act is not improper exercise of police power.
2. Police power is the most insistent and least limitable of all powers of the
gov’t. it has been described as a power coextensive with self-protection and
constitutes the law of overruling necessity.
3. Act o, 1639 is designed to promote peace and order in the non-Christian tribes
so as to remove all obstacles to their moral and intellectual growth and eventually
to hasten their equalization and unification with the rest of their Christian
brothers.
II. The act is not discriminatory
1. The law does not seek to mark the non-Christian tribes as “an inferior or less
capable race.” All measures thus are adopted in the promotion of the public policy
towards them rest upon the recognition of their inherent right to equality in the
enjoyment of those privileges enjoyed by their Christian brothers.
 
JUDGMENT:
 Judgment of the COFI is AFFIRMED.

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