Section 1, Article III of the 1987 Philippine Constitution, states that:
"No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws."
The equal protection clause ensures that individuals in similar circumstances are treated equally by the law. It prohibits the state from enacting discriminatory laws or enforcing laws in a discriminatory manner unless a legitimate classification exists.
Principles of Equal Protection
1. Equality Among Equals: The equal protection clause does not require absolute equality, but it mandates that persons who are similarly situated must be treated alike. A valid classification may be allowed if it:
a. rests on substantial distinctions;
b. is germane to the purpose of the law;
c. is not limited to existing conditions only;
d. applies equally to all members of the same class.
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2. Valid Classification: A law or government action is not invalid merely because it classifies individuals, but the classification must be reasonable and based on real and substantial differences. The classification must also bear a rational connection to the objective of the law.
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The right to equal protection of the laws in the Philippines ensures that no individual or group is subjected to arbitrary classifications or discriminatory laws.
Philippine jurisprudence provides that classifications made by the government must be based on substantial distinctions, related to the purpose of the law, and must apply equally to all members of the same class. The equal protection clause remains a vital constitutional safeguard against inequality and discrimination.
Cases
G.R. No. L-45685, November 16, 1937
This is one of the earliest and most important cases on equal protection in Philippine jurisprudence.
The Supreme Court declared unconstitutional a provision of the Probation Law that allowed provincial boards to decide whether to apply the law in their respective provinces.
The Court ruled that the law violated the equal protection clause because it created arbitrary distinctions between individuals similarly situated, based on their place of residence.
G.R. No. 148208, December 15, 2004
In this case, the Central Bank Employees Association challenged the constitutionality of a law limiting the payment of benefits to employees of the Bangko Sentral ng Pilipinas (BSP).
The Supreme Court struck down the law, ruling that it violated the equal protection clause because it singled out BSP employees, depriving them of benefits granted to employees of other government financial institutions.
The Court held that the classification had no reasonable basis and discriminated against a specific group of government employees.
G.R. No. L-7995, May 31, 1957
This case challenged Republic Act No. 1180, which prohibited aliens from engaging in retail trade.
The Supreme Court upheld the law, ruling that the classification between Filipinos and aliens was valid because it was based on a substantial distinction and was germane to the protection of Filipino business interests.
The Court emphasized that the equal protection clause allows classifications as long as they are reasonable and not arbitrary.
G.R. No. L-27833, April 18, 1969
This case involved the constitutionality of Republic Act No. 4880, which prohibited the premature nomination of candidates for election.
Petitioners claimed that it violated the equal protection clause by discriminating against candidates who were nominated early.
The Supreme Court upheld the law, ruling that the classification was reasonable because it aimed to level the playing field and prevent candidates with early nominations from gaining undue advantage over others.
G.R. No. L-65366, November 9, 1983
This case addressed the denial of a permit to hold a peaceful assembly by the mayor of Manila.
The Supreme Court held that such denial violated the equal protection clause because it arbitrarily deprived certain individuals of their constitutional right to peaceful assembly.
The Court emphasized that laws and actions that affect constitutional rights must be applied equally and fairly to all.
G.R. No. 161107, March 12, 2014
In this case, the issue was the unequal treatment of male and female students in a Catholic school that prohibited pregnant students from graduating but did not impose similar penalties on male students who fathered children.
The Supreme Court ruled that the policy violated the equal protection clause because it discriminated against female students based on gender, which was an arbitrary classification.
G.R. No. 203335, February 18, 2014
This case dealt with the constitutionality of the Cybercrime Prevention Act of 2012.
The petitioners argued that the provisions of the law penalizing online libel violated the equal protection clause because it singled out online libel for harsher penalties compared to libel in traditional media.
The Supreme Court agreed, ruling that imposing a higher penalty for online libel had no rational basis, thus violating the equal protection clause.