Case Summary (G.R. No. 133705)
Key Dates
• January 25, 1937 – Alleged offense date (possession of prohibited gin)
• Trial and conviction in Justice of the Peace Court (fine of ₱5 or subsidiary imprisonment)
• Appeal to the Court of First Instance – conviction and fine increased to ₱50 or subsidiary imprisonment
• May 5, 1939 – Decision by the Supreme Court of the Philippines
Applicable Law and Constitutional Basis
• Act No. 1639, Sections 2 and 3 (prohibiting non-Christian tribal members from possessing intoxicating liquors other than native wines)
• Constitutional analysis under the 1935 Philippine Constitution (equal protection, due process, police power)
Facts and Procedural History
• Cayat was charged with willfully and unlawfully possessing one bottle of A-l-1 gin in Baguio City, in violation of Act No. 1639.
• He filed a demurrer to the information, which was overruled; he then admitted the factual allegations but pleaded not guilty.
• The Court of First Instance found him guilty, imposing a ₱50 fine (or subsidiary imprisonment). He appealed to the Supreme Court.
Issue Presented
Whether Act No. 1639, which singles out members of non-Christian tribes for prohibition against certain intoxicating liquors, violates:
- The equal protection clause;
- The due process clause; and
- The limits of the State’s police power.
Equal Protection and Reasonable Classification
• Classification must rest on substantial distinctions, be germane to the law’s purpose, endure beyond temporary conditions, and apply equally to all within the class.
• The term “non-Christian tribes” denotes a low grade of civilization and geographical isolation, not race or religion per se.
• The classification targets a specific social condition—lack of acculturation to modern customs—and is reasonably related to the legislative aim of preserving peace and order among the tribes.
• The existence of some assimilated individuals does not negate the validity of a general classification.
Due Process Considerations
• Due process under the 1935 Constitution requires that laws be:
- Enacted by the legislature;
- Reasonable;
- Enforced by prescribed procedures; and
- Applied uniformly to all persons similarly situated.
• The provision authorizing seizure and destruction of contraband liquor by police need not afford pre-seizure hearings where administrative discretion and public welfare justify summary action.
Police Power and Public Welfare
• The police power encompasses measures to promote health, morals, peace, and general welfare and is coextensive with self-protection.
• Act No. 1639 is a valid exercise of police power aimed at preventing liquor-induced disorder among culturally di
Case Syllabus (G.R. No. 133705)
Procedural History and Facts
- Cayat, a native of Baguio, Benguet, Mountain Province, was prosecuted for violating sections 2 and 3 of Act No. 1639.
- Before the Justice of the Peace Court of Baguio, he was convicted and sentenced to pay a fine of ₱5 or suffer subsidiary imprisonment if insolvent.
- On appeal, the Court of First Instance filed information charging him with willfully receiving, acquiring, and possessing one bottle of A-11 gin on or about January 25, 1937, in Baguio.
- Cayat’s demurrer to the information was overruled. He admitted the facts but pleaded not guilty, relying on his demurrer, and submitted the case on the pleadings.
- The trial court found him guilty and imposed a fine of ₱50 or subsidiary imprisonment if insolvent.
- Cayat appealed to the Supreme Court, challenging the constitutionality of Act No. 1639.
Statutory Provisions
- Section 2 of Act No. 1639 prohibits any member of a non-Christian tribe from buying, receiving, possessing, or drinking ardent spirits, ale, beer, wine, or intoxicating liquors of any kind, except native wines and liquors customarily made before the Act.
- The same section imposes on police officers or authorized government agents the duty to seize and destroy unlawfully possessed prohibited liquors.
- Section 3 prescribes penalties for violation of sections 1 or 2: a fine not exceeding ₱200 or imprisonment up to six months, at the court’s discretion.
Appellant’s Contentions
- The law is discriminatory and denies equal protection under the Constitution.
- The seizure and destruction provision violates due process.
- The statute constitutes an improper exercise of the police power.
Government Policy and Historical Context
- Since 1551, the Spanish Government pursued a policy of civilizing non-Christian tribes by concentrating them in reducciones for