SUBJECT:

Constitutional
Law II

TOPIC: People vs.

Cayat

Date Made:
February 7, 2016

Digest Maker:
Ruth F. Melicor

CASE NAME: People vs. Cayat

PONENTE: Chico-Nazario, J
Case Date: May 5,1939
Case Summary:
The accused was convicted by the trial court for violating Sec 2 and 3 of Act 1639,
which prohibited members of non-Christian tribes from having intoxicating liquors.
He was found being in possession of one bottle of gin. He appealed the decision to
the Supreme Court by stating that the law was unconstitutional by being violative
of the due process clause, equal protection clause, and being an abuse of police
power. The court upheld the unconstitutionality of the law. First, it was held that
the statute did not violate the equal protection of the laws, since it safely me the
standards of reasonable classification, namely:
o Must rest on substantial distinction
o Must be germane to the purposes of the law
o Must not be limited to existing conditions only
o Must apply equally to all members of the same class
It was also found that the law did not violate equal protection, since a notice and
hearing was not necessary for the authorities to confiscate the liquor, and that it
was a valid exercise of police power since private interests must yield to the
interests of the nation.
Rule of Law:
Sections 2 and 3 of Act No. 1639 read:
SEC. 2. It shall be unlawful for any native of the Philippine Islands who is a member of a
non-Christian tribe within the meaning of the Act Numbered Thirteen hundred and
ninety-seven, to buy, receive, have in his possession, or drink any ardent spirits, ale,
beer, wine, or intoxicating liquors of any kind, other than the so-called native wines and
liquors which the members of such tribes have been accustomed themselves to make
prior to the passage of this Act, except as provided in section one hereof; and it shall be
the duty of any police officer or other duly authorized agent of the Insular or any
provincial, municipal or township government to seize and forthwith destroy any such
liquors found unlawfully in the possession of any member of a non-Christian tribe.
SEC. 3. Any person violating the provisions of section one or section two of this Act shall,
upon conviction thereof, be punishable for each offense by a fine of not exceeding two
hundred pesos or by imprisonment for a term not exceeding six months, in the discretion
of the court.
Detailed Facts:
The accused, Cayat, was a native of Baguio, Benguet Mountain Province. He was
sentenced to pay a fine of five pesos or suffer subsidiary imprisonment for
violation of Act No. 1639. (He was found to have possession of one bottle of gin)
Under the law, members of non-Christian tribe cannot, buy, possess, or drink
intoxicating liquors
Trial court convicted him
The defendant challenges the Acts constitutionality on three grounds:
o (1) it is discriminatory and denies the equal protection of the laws
o it is violative of the due process clause
o it is improper exercise of the police power of the state
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Counsel for defendant argued that the non-Christian tribes were being
discriminated against.

WoN the Law is unconstitutional No

WoN the provision empowering any police officer to seize and destroy the prohibited
liquors is violative of due process of law -NO
WoN the act is an improper exercise of police power. - No
Holding:

The government wishes to guide these tribes into the path of civilization.
The guaranty of equal protection of laws is not violated by a legislation based on
reasonable classification
o Must rest on substantial distinction
o Must be germane to the purposes of the law
o Must not be limited to existing conditions only
o Must apply equally to all members of the same class
Act 1639 satisfies these requirements. The classification is real and substantial, not
based on accident of birth but upon the degree of civilization and culture. This
distinction is reasonable
It is germane to the purposes of the law to insure peach and order in and among
non-Christian tribes, since free use have resulted in crimes, not aiding the govt in
its efforts
Law is not limited in its application to conditions existing at the time of enactment.
It is intended to apply for all times as long as those condition exist. Legislation
understood that the civilization process is a slow one.
The act applies equal to all members of the class.

Second Issue:
The provision is not involved in the case at bar. Furthermore, notice and hearing is
not always necessary
Due process of law means simply:
o (1) that there shall be a law prescribed in harmony with the general powers
of the legislative department of the government;
o (2) that it shall be reasonable in its operation;
o (3) that it shall be enforced according to the regular methods of procedure
prescribed;
o (4) that it shall be applicable alike to all citizens of the state or to all of the
class.
Third Issue:
It is a proper exercise of police power. It is designed to promote peace and order
for the tribes, and remove obstacles for their growth.
It does not seek to mark them as an inferior race.
There can be no true equality under the law; when public safety or the public
morals require the discontinuance of a certain practice by certain people, the
intent of the Legislature cannot be stopped.
Private interests must yield to the interest of the nation
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Ruling
Judgment is affirmed, with costs against appellant.
Other Opinions:
NONE

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