Case Digest (G.R. No. 110068) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Cayat, G.R. No. 45987, decided on May 5, 1939 under the 1935 Commonwealth Constitution, the appellant, Alejandro Cayat, a native of Baguio, Benguet, was charged with violating Act No. 1639, sections 2 and 3, which prohibits members of the non-Christian tribes from buying, receiving, possessing, or drinking intoxicating liquors other than their traditional native wines. On or about January 25, 1937, in the City of Baguio, Cayat was found in possession of one bottle of A-111 gin. The Justice of the Peace of Baguio convicted him and imposed a fine of five pesos or subsidiary imprisonment. Upon appeal to the Court of First Instance, a formal information was filed restating the charge. Cayat interposed a demurrer challenging the law’s constitutionality, which the trial court overruled. At trial, he admitted the factual allegations but relied on his demurrer grounds, pleading not guilty. The lower court convicted him and increased the fine to fifty pes Case Digest (G.R. No. 110068) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Charge
- Defendant: Cayat, a native of Baguio, member of a non-Christian tribe.
- Allegation: Willfully, unlawfully, and illegally received, acquired, and possessed one bottle of A-1-1 gin in violation of Act No. 1639, secs. 2 and 3.
- Procedural History
- Justice of the Peace Court of Baguio: Convicted Cayat; imposed P 5 fine (or subsidiary imprisonment).
- Court of First Instance: Filed amended information (date: Jan. 25, 1937); overruled demurrer; Cayat admitted facts but pleaded not guilty; found guilty; imposed P 50 fine (or subsidiary imprisonment).
- Supreme Court Appeal: Cayat challenges constitutionality of Act No. 1639; case submitted on pleadings.
- Statutory Provisions (Act No. 1639)
- Section 2: Prohibits non-Christian tribe members from buying, receiving, possessing, or drinking intoxicating liquors other than their native wines; authorizes police seizure and destruction of prohibited liquors.
- Section 3: Penalty for violation—fine up to P 200 or imprisonment up to six months, at court’s discretion.
Issues:
- Does Act No. 1639’s classification of non-Christian tribes deny equal protection of the laws?
- Does the seizure-and-destruction provision violate due process of law?
- Is the statute an improper exercise of the police power of the State?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)