Title
Rubi vs. Provincial Board of Mindoro
Case
G.R. No. 14078
Decision Date
Mar 7, 1919
Manguianes challenged forced relocation to Tigbao under Section 2145; Court upheld law, ruling it constitutional and necessary for public welfare and integration.

Case Summary (G.R. No. 14078)

Legislative and Historical Background

Spanish colonial ordinances (Laws I, VIII, IX, XIII, XV, XXI of the Laws of the Indies) mandated reducciones to concentrate indigenous tribes for evangelization and protection. A royal decree of 1881 reaffirmed reduction of pagan races under common law, prescribing executive‐defined rules and penalties. After U.S. acquisition, President McKinley’s 1900 Instructions advocated for regulated tribal reservations akin to those for American Indians. The Philippine Bill (1902) and Jones Law (1916) continued distinct legislative treatment of “non-Christian tribes” under federal organic statutes. Statutory predecessors—Act No. 547 and others—specifically empowered provincial governors, with Interior Department approval, to relocate Mangyanes, prescribing penalties for noncompliance. These provisions were codified in Administrative Codes of 1916 and 1917.

Terminology and Classification of “Non-Christian”

Although the term “non-Christian” might connote religious belief, legislative and executive practice treats it as a proxy for degree of civilization and mode of life. Multiple acts and administrative regulations define “non-Christian” inhabitants as tribal or semi-tribal populations living apart from organized municipalities and lacking sufficient cultural advancement for municipal governance. Official correspondence from Interior Secretaries and Internal Revenue circulars clarify that baptism or professed faith does not alter classification; the decisive factor remains tribal connection, isolation from civilization, and nomadic or uncontrolled habitation.

Status of the Manguianes

The Manguianes of Mindoro, numbering some 15,000, exhibit a Negrito‐derived, semi-nomadic, low‐culture lifestyle with scant desire for permanent settlement or municipal government. Prior failed educational and evangelistic efforts, forest depredations through shifting‐cultivation (“caingin”), and lack of law enforcement access motivated provincial action. Act No. 547’s preamble explicitly cites necessity of compulsory settlement for educational success, protection of public forests, introduction of “civilized customs,” and ensuring law and order.

Comparative Framework: American Indian Reservations

U.S. Supreme Court decisions (Worcester v. Georgia, U.S. v. Kagama, U.S. v. Sandoval) recognize plenary congressional power over dependent Indian tribes, characterizing them as wards under guardian‐ward doctrine, subject to legislative and executive regulation for civilizing and protecting tribal populations. Although these cases involved treaty-based recognition of tribal sovereignty and defined reservations, they establish that a sovereign may, in furtherance of a coherent policy, confine or segregate a dependent people for their own welfare and the public good without judicial interference.

Constitutional Objections and Analysis

  1. Delegation of Legislative Power: Delegation doctrine permits vesting discretion in executive or local officials to administer laws and make fact determinations (test of necessity and relevant standards defined by Legislature). Section 2145 confers execution discretion—site selection and timing—subject to Department Head and provincial board oversight, fitting within permissible delegation.
  2. Religious Discrimination: The classification targets tribal mode of life, not religious belief. “Non-Christian” is a cultural designation, not a test of religious faith, avoiding unconstitutional religious discrimination.
  3. Due Process and Equal Protection (§ 3, Organic Act of 1916; Jones Law): Relocation under § 2145 is enacted by law, serves rational governmental objectives (education, law and order, resource protection, public welfare), and applies equally to all tribal inhabitants, satisfying due process and equal protection requirements. Notice, hearing, and judicial trial are not prerequisites for administrative measures taken under valid poli

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