People vs.

Cayat

Facts: Republic Act No. 1639 is challenged by herein petitioner for it violates the due process and equal protection
clause. The said act prohibits any member of a non-Christian tribe to buy, receive, have in his possession, or drink
any intoxicating liquors which they are not accustomed with. Sec. 2 of the act describes the said law and section 3
contains the punishment for whoever violates the said act.

Issue: Whether or not it violates the due process and equal protection clause

Held: It is an established principle of constitutional law that the guaranty of the equal protection of the laws is not
equal protection of the laws is not violated by a legislation based on reasonable classification. And the
classification, to be reasonable, (1) must rest on substantial distinctions; (2) must be germane to the purposes of
the law; (3) must not be limited to existing conditions only; and (4) must apply equally to all members of the same
class. The said act satisfies these requirements. "The term 'non-Christian tribes' refers, not to religious belief, but,
in a way, to the geographical area, and, more directly, to natives of the Philippine Islands of a low grade of
civilization, usually living in tribal relationship apart from settled communities. Act No. 1639, as above stated, 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. Its ultimate purpose can be no other than to unify the Filipino people with a view to a greater
Philippines.

PASEI vs. Drilon

Facts: Department Order No.1, Series of 1998 is being challenged by Petitioner Philippine Association of Service
Exporters, Inc. (PASEI). PASEI is engaged in the recruitment of Filipino workers, male and female overseas. The said
order discriminates male and female workers for it does not apply to all Filipino workers but only to domestic
helpers and females with similar skills. Petitioner also invoked Sec. 13 of Article 13 of the Constitution, providing
for worker participation in policy and decision-making processes affecting their rights and benefits as may be
provided by law. In response, the Solicitor General on behalf of DOLE stated that the said order is a legitimate
exercise of police power, for there are cases and evidences that those Filipina workers, as compared to the Filipino
workers, are experiencing abuse overseas.

Issue: Whether or not Department Order No. 1 violates the equal protection clause

Held: The Court finds, finally, the impugned guidelines to be applicable to all female domestic overseas workers.
That it does not apply to "all Filipina workers" is not an argument for unconstitutionality. Had the ban been given
universal applicability, then it would have been unreasonable and arbitrary. For obvious reasons, not all of them
are similarly circumstanced. What the Constitution prohibits is the singling out of a select person or group of
persons within an existing class, to the prejudice of such a person or group or resulting in an unfair advantage to
another person or group of persons. Where the classification is based on such distinctions that make a real
difference as infancy, sex, and stage of civilization of minority groups, the better rule, it would seem, is to
recognize its validity only if the young, the women, and the cultural minorities are singled out for favourable
treatment. There would be an element of unreasonableness if on the contrary their status that calls for the law
ministering to their needs is made the basis of discriminatory legislation against them. If such be the case, it would
be difficult to refute the assertion of denial of equal protection." In the case at bar, the assailed Order clearly
accords protection to certain women workers, and not the contrary.

DUMLAO vs. COMELEC

Facts: Petitioner questions the constitutionality of section 4 of Batas Pambansa Blg. 52 as discriminatory and
contrary to the equal protection and due process guarantees of the Constitution. Section 4 provided that any
retired municipal or provincial city official that already received retirement benefits and is 65 years of age shall not
be qualified to run for the same local elective office from which he has retired.

Issue: Whether or Not Sec. 4 of BP.52 is unconstitutional being contrary to the equal protection and due process
rights.

Held: No. The guarantee of equal protection is subject to rational classification based on reasonable and real
differentiations. In the present case, employees 65 years of age have been classified differently from younger
employees. The former are subject to compulsory retirement while the latter are not. Retirement is not a
reasonable disqualification for elective local officials because there can be retirees who are even younger and a 65
year old retiree could be as good as a 65 year old official who is not a retiree. But there is reason to disqualify a 65
year old elective official who is trying to run for office because there is the need for new blood to assume
relevance. When an official has retired he has already declared himself tired and unavailable for the same
government work.

Telecommunications and Broadcast Attorneys of the Philippines vs. COMELEC

Facts: Petitioner Telecommunications and Broadcast Attorneys of the Philippines, Inc. (TELEBAP) is an organization
of lawyers of radio and television broadcasting companies. It was declared to be without legal standing to sue in
this case as, among other reasons, it was not able to show that it was to suffer from actual or threatened injury as
a result of the subject law. Petitioner GMA Network, on the other hand, had the requisite standing to bring the
constitutional challenge. Petitioner operates radio and television broadcast stations in the Philippines affected by
the enforcement of Section 92, B.P. No. 881.

Petitioners challenge the validity of Section 92, B.P. No. 881 which provides:

Comelec Time- The Commission shall procure radio and television time to be known as the Comelec Time
which shall be allocated equally and impartially among the candidates within the area of coverage of all radio and
television stations. For this purpose, the franchise of all radio broadcasting and television stations are hereby
amended so as to provide radio or television time, free of charge, during the period of campaign.

Petitioner contends that while Section 90 of the same law requires COMELEC to procure print space in newspapers
and magazines with payment, Section 92 provides that air time shall be procured by COMELEC free of charge.
Thus it contends that Section 92 singles out radio and television stations to provide free air time. Petitioner claims
that it suffered losses running to several million pesos in providing COMELEC Time in connection with the 1992
presidential election and 1995 senatorial election and that it stands to suffer even more should it be required to do
so again this year. Petitioners claim that the primary source of revenue of the radio and television stations is the
sale of air time to advertisers and to require these stations to provide free air time is to authorize unjust taking of
private property. According to petitioners, in 1992 it lost P22,498,560.00 in providing free air time for one hour
each day and, in this years elections, it stands to lost P58,980,850.00 in view of COMELECs requirement that it
provide at least 30 minutes of prime time daily for such.

Issue: Whether or not Section 92 of B.P. No. 881 denies radio and television broadcast companies the equal
protection of the laws.
Held: Petitioners argument is without merit. All broadcasting, whether radio or by television stations, is licensed
by the government. Airwave frequencies have to be allocated as there are more individuals who want to
broadcast that there are frequencies to assign. Radio and television broadcasting companies, which are given
franchises, do not own the airwaves and frequencies through which they transmit broadcast signals and images.
They are merely given the temporary privilege to use them. Thus, such exercise of the privilege may reasonably be
burdened with the performance by the grantee of some form of public service. In granting the privilege to operate
broadcast stations and supervising radio and television stations, the state spends considerable public funds in
licensing and supervising them. Petitioners assertion therefore that 92 of B.P. Blg. 881 denies them the equal
protection of the law has no basis. In addition, their plea that 92 (free air time) and 11(b) of R.A. No. 6646 (ban
on paid political ads) should be invalidated would pave the way for a return to the old regime where moneyed
candidates could monopolize media advertising to the disadvantage of candidates with less resources. That is
what Congress tried to reform in 1987 with the enactment of R.A. No. 6646. We are not free to set aside the
judgment of Congress, especially in light of the recent failure of interested parties to have the law repealed or at
least modified.

Lacson vs. Executive Secretary

Facts: The constitutionality of Sections 4 and 7 of Republic Act No. 8249 an act which further defines the
jurisdiction of the Sandiganbayan is being challenged in this petition for prohibition and mandamus. Petitioner
Panfilo Lacson, joined by petitioners-intervenors Romeo Acop and Francisco Zubia, Jr., also seeks to prevent the
Sandiganbayan from proceedings with the trial of Criminal Cases Nos. 23047-23057 (for multiple murder) against
them on the ground of lack of jurisdiction. Eleven persons believed to be members of the Kuratong Baleleng gang,
an organized crime syndicate involved in bank robberies, were slain by elements of the Anti-Bank Robbery and
Intelligence Task Group (ABRITG). Among those included in the ABRITG were petitioners and petitioner-
intervenors. Acting on a media expose of SPO2 Eduardo delos Reyes, a member of the Criminal Investigation
Command, that what actually transpired was a summary execution and not a shoot-out between the Kuratong
Baleleng gang members and the ABRITG, Ombudsman Aniano Desierto formed a panel of investigators to
investigate the said incident. Said panel found the incident as a legitimate police operation. However, a review
board modified the panels finding and recommended the indictment for multiple murder against twenty-six
respondents including herein petitioner, charged as principal, and herein petitioner-intervenors, charged as
accessories. After a reinvestigation, the Ombudsman filed amended informations before the Sandiganbayan,
where petitioner was charged only as an accessory.

The accused filed separate motions questioning the jurisdiction of the Sandiganbayan, asserting that under the
amended informations, the cases fall within the jurisdiction of the Regional Trial Court pursuant to Section 2 of
R.A. 7975. They contend that the said law limited the jurisdiction of the Sandiganbayan to cases where one or
more of the principal accused are government officals with Salary Grade 27 or higher, or PNP officials with rank
of Chief Superintendent or higher. Thus, they did not qualify under said requisites. However, pending resolution
of their motions, R.A. 8249 was approved amending the jurisdiction of the Sandiganbayan by deleting the word
principal from the phrase principal accused in Section 2 of R.A. 7975. Petitioner questions the constitutionality
of Section 4 of R.A. 8249, including Section 7 which provides that the said law shall apply to all cases pending in any
court over which trial has not begun as of the approval hereof.

Issue: Whether or not Sections 4 and 7 of R.A. 8249 violate the petitioners right to due process and the equal
protection clause of the Constitution as the provisions seemed to have been introduced for the Sandiganbayan to
continue to acquire jurisdiction over the Kuratong Baleleng case.
Held: Petitioner and intervenors posture that Sections 4 and 7 of R.A. 8249 violate their right to equal protection
of the law is too shallow to deserve merit. No concrete evidence and convincing argument were presented to
warrant such a declaration. Every classification made by the law is presumed reasonable and the party who
challenges the law must present proof of arbitrariness. The classification is reasonable and not arbitrary when the
following concur: (1) it must rest on substantial distinction; (2) it must be germane to the purpose of the law; (3)
must not be limited to existing conditions only, and (4) must apply equally to all members of the same class; all of
which are present in this case. Paragraph a of Section 4 provides that it shall apply to all cases involving certain
public officials and under the transitory provision in Section 7, to all cases pending in any court. Contrary to
petitioner and intervenors argument, the law is not particularly directed only to the Kuratong Baleleng cases. The
transitory provision does not only cover cases which are in the Sandiganbayan but also in any court.

International School Alliance vs. Quisumbing

Facts: Private respondent International School, Inc. (the School, for short), pursuant to Presidential Decree 732, is a
domestic educational institution established primarily for dependents of foreign diplomatic personnel and other
temporary residents. To enable the School to continue carrying out its educational program and improve its
standard of instruction, Section 2(c) of the same decree authorizes the School to employ its own teaching and
management personnel selected by it either locally or abroad, from Philippine or other nationalities, such
personnel being exempt from otherwise applicable laws and regulations attending their employment, except laws
that have been or will be enacted for the protection of employees. Accordingly, the School hires both foreign and
local teachers as members of its faculty, classifying the same into two: (1) foreign-hires and (2) local-hires. The
School grants foreign-hires certain benefits not accorded local-hires. These include housing, transportation,
shipping costs, taxes, and home leave travel allowance. Foreign-hires are also paid a salary rate twenty-five
percent (25%) more than local-hires. The School justifies the difference on two "significant economic
disadvantages" foreign-hires have to endure, namely: (a) the "dislocation factor" and (b) limited tenure.

Issue: Whether or Not the grants provided by the school to foreign hires and not to local hires discriminative of
their constitutional right to the equal protection clause

Held: While we recognize the need of the School to attract foreign-hires, salaries should not be used as an
enticement to the prejudice of local-hires. The local-hires perform the same services as foreign-hires and they
ought to be paid the same salaries as the latter. For the same reason, the "dislocation factor" and the foreign-hires'
limited tenure also cannot serve as valid bases for the distinction in salary rates. The dislocation factor and limited
tenure affecting foreign-hires are adequately compensated by certain benefits accorded them which are not
enjoyed by local-hires, such as housing, transportation, shipping costs, taxes and home leave travel allowances.
The Constitution enjoins the State to "protect the rights of workers and promote their welfare," "to afford labor
full protection." The State, therefore, has the right and duty to regulate the relations between labor and
capital. These relations are not merely contractual but are so impressed with public interest that labor contracts,
collective bargaining agreements included, must yield to the common good. Should such contracts contain
stipulations that are contrary to public policy, courts will not hesitate to strike down these stipulations.

In this case, we find the point-of-hire classification employed by respondent School to justify the distinction in the
salary rates of foreign-hires and local hires to be an invalid classification. There is no reasonable distinction
between the services rendered by foreign-hires and local-hires. The practice of the School of according higher
salaries to foreign-hires contravenes public policy and, certainly, does not deserve the sympathy of this Court.

Ormoc Sugar Company Inc., vs. Treasurer of Ormoc

Facts: On January 29, 1964, the Municipal Board of Ormoc City passed 1 Ordinance No. 4, Series of 1964, imposing
"on any and all productions of centrifugal sugar milled at the Ormoc Sugar Company, Inc., in Ormoc City a
municipal tax equivalent to one per centum (1%) per export sale to the United States of America and other foreign
countries." Payments for said tax were made, under protest, by Ormoc Sugar Company, Inc. on March 20, 1964 for
P7,087.50 and on April 20, 1964 for P5,000, or a total of P12,087.50. The petitioner herein challenged the
ordinance, stating that it violates the equal protection clause and the rule of uniformity of taxation.

Issue: Whether or not the ordinance violates the constitutional limits on the power of taxation, specifically the
equal protection clause and rule of uniformity of taxation.

Held: The Constitution in the bill of rights provides: ". . . nor shall any person be denied the equal protection of the
laws." (Sec. 1 [1], Art. III) In Felwa vs. Salas, We ruled that the equal protection clause applies only to persons or
things identically situated and does not bar a reasonable classification of the subject of legislation, and a
classification is reasonable where (1) it is based on substantial distinctions which make real differences; (2) these
are germane to the purpose of the law; (3) the classification applies not only to present conditions but also to
future conditions which are substantially identical to those of the present; (4) the classification applies only to
those who belong to the same class.

A perusal of the requisites instantly shows that the questioned ordinance does not meet them, for it taxes only
centrifugal sugar produced and exported by the Ormoc Sugar Company, Inc. and none other. At the time of the
taxing ordinance's enactment, Ormoc Sugar Company, Inc., it is true, was the only sugar central in the city of
Ormoc. Still, the classification, to be reasonable, should be in terms applicable to future conditions as well. The
taxing ordinance should not be singular and exclusive as to exclude any subsequently established sugar central, of
the same class as plaintiff, for the coverage of the tax. As it is now, even if later a similar company is set up, it
cannot be subject to the tax because the ordinance expressly points only to Ormoc City Sugar Company, Inc. as the
entity to be levied upon.

Philippine Judges Association vs. Prado

Facts: The main target of this petition is Section 35 of R.A. No. 7354 as implemented by the Philippine Postal
Corporation through its Circular No. 92-28. These measures withdraw the franking privilege from the Supreme
Court, the Court of Appeals, the Regional Trial Courts, the Metropolitan Trial Courts, the Municipal Trial Courts,
and the Land Registration Commission and its Registers of Deeds, along with certain other government offices. It is
alleged that R.A. No. 7354 is discriminatory because while withdrawing the franking privilege from the Judiciary, it
retains the same for the President of the Philippines, the Vice President of the Philippines; Senators and Members
of the House of Representatives, the Commission on Elections; former Presidents of the Philippines; the National
Census and Statistics Office; and the general public in the filing of complaints against public offices and officers.
The respondents counter that there is no discrimination because the law is based on a valid classification in
accordance with the equal protection clause. In fact, the franking privilege has been withdrawn not only from the
Judiciary but also the Office of Adult Education, the Institute of National Language; the Telecommunications Office;
the Philippine Deposit Insurance Corporation and other offices of the government.

Issue: Whether or not Section 35 of RA 7354 violates the equal protection clause.

Held: It is worth observing that the Philippine Postal Corporation, as a government-controlled corporation, was
created and is expected to operate for the purpose of promoting the public service. Among the services it should
be prepared to extend is free carriage of mail for certain offices of the government that need the franking privilege
in the discharge of their own public functions. If the problem of the respondents is the loss of revenues from the
franking privilege, the remedy, it seems to us, is to withdraw it altogether from all agencies of government,
including those who do not need it. The problem is not solved by retaining it for some and withdrawing it from
others, especially where there is no substantial distinction between those favored, which may or may not need it
at all, and the Judiciary, which definitely needs it. The problem is not solved by violating the Constitution.

In lumping the Judiciary with the other offices from which the franking privilege has been withdrawn, Section 35
has placed the courts of justice in a category to which it does not belong. If it recognizes the need of the President
of the Philippines and the members of Congress for the franking privilege, there is no reason why it should not
recognize a similar and in fact greater need on the part of the Judiciary for such privilege. While we may appreciate
the withdrawal of the franking privilege from the Armed Forces of the Philippines Ladies Steering Committee, we
fail to understand why the Supreme Court should be similarly treated as that Committee. And while we may
concede the need of the National Census and Statistics Office for the franking privilege, we are intrigued that a
similar if not greater need is not recognized in the courts of justice. We are unable to agree with the respondents
that Section 35 of R.A. No. 7354 represents a valid exercise of discretion by the Legislature under the police power.
On the contrary, we find its repealing clause to be a discriminatory provision that denies the Judiciary the equal
protection of the laws guaranteed for all persons or things similarly situated. The distinction made by the law is
superficial. It is not based on substantial distinctions that make real differences between the Judiciary and the
grantees of the franking privilege. This is not a question of wisdom or power into which the Judiciary may not
intrude. It is a matter of arbitrariness that this Court has the duty and power to correct.

Quinto vs. Comelec

Facts: In preparation for the upcoming 2010 National Elections, the Commission on Elections issued Resolution No.
8678 to govern the filing of Certificates of Candidacy for national and local positions. Section 4 of the Resolution
reads:

Sec. 4. Effects of Filing of Certificates of Candidacy. (a) Any person holding a public appointive office or position,
including active members of the Armed Forces of the Philippines, and other officers and employees in
government-owned or controlled corporations, shall be considered ipso facto resigned from his office upon the
filing of his certificate of candidacy. (b) Any person holding an elective office or position shall not be considered
resigned upon the filing of his certificate of candidacy for the same or any other elective office or position.

Since they intend to run for elective office in the 2010 Elections, Department of Environment and Natural
Resources Undersecretary Eleazar Quinto (running for Pangasinancongressman) and DENR Land Management
Bureau Director Gerino Tolentino Jr. (running for Manila councilor) filed a petition for certiorari and prohibition to
nullify sec. 4(a) of Resolution 8678. According to them, imposing automatic resignation against appointive officials
who file their certificates of candidacy is offensive to the equal protection clause of the Constitution of the
Philippines because it gives an undue advantage to elective officials who are allowed to remain in office despite
the filing of their certificates of candidacy.

Issue: Whether or not the Resolution violates the equal protection clause

Held: The original ruling also saw no valid justification in applying the automatic resignation rule exclusively to
appointive officials and not to elected ones. The classification between the two classes of officials failed to pass the
test of equal protection, which requires a valid classification to be: (1) based upon substantial distinctions; (2)
germane to the purposes of the law; (3) not limited to existing conditions only; and (4) applicable equally to all
members of the class.
The first ponencia held that the classification under section 4 of Resolution 8678 must be struck down because it
fails to satisfy the second requisite that the classification must be germane to the purposes of the law. If the
purpose of the automatic resignation rule is to prevent either undue influence or neglect of duty on the part of the
candidate, there is no reason to exclude elected officials from the coverage of the law. The original majority agreed
that these fears are equally applicable to elected and appointive officials alike, thus, treating the one differently
from the other should fail the test of equal protection.