Equal Protection Clause of the Constitution; Classification also Applies to Future Conditions

     TOPICS:

1. Requisites of a valid classification

Ormoc Sugar Company, Inc. vs. Treasurer of Ormoc City

FACTS:

The Municipal Board of Ormoc City passed Ordinance No. 4, s. 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.”

Petitioner filed a case before the CFI of Leyte against Ormoc City, alleging that the ordinance violated the equal protection clause of the Constitution.

ISSUE:

Whether the ordinance violates the equal protection clause of the Constitution.

RULING: 

Yes, the ordinance is violative of the equal protection clause of the Constitution. 

Jurisprudence provides that the subject of legislation must be reasonable for it not to be violative of the equal protection clause of the Constitution, such that it must be based on substantial distinctions; germane to the purpose of the law; the classification applies not only to present conditions but also to future conditions which are substantially identical to those of the present; and that the classification applies only to those who belong to the same class. 

In this case, Ordinance No. 4, s. 1964 imposes taxes only on centrifugal sugar produced and exported by the Ormoc Sugar Company, Inc. and none other. The tax ordinance is exclusive to Ormoc Sugar Company, Inc. and does not apply to other identical sugar central which may be established in the future. 

Therefore, the ordinance is violative of equal protection as it applies only to present conditions and does not apply to future conditions which are substantially identical to those of the present. 

  

STATUTORY CONSTRUCTION DISCUSSION

1.  What does the equal protection clause of the Constitution provide?

The Constitution in the bill of rights provides that no person shall be denied the equal protection of the laws.

2. What are the requisites for a valid classification under the equal protection clause of the Constitution?

The 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.

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