Title
Rubi vs. Provincial Board of Mindoro
Case Decision Date
G.R. No. 14078 Mar 7, 1919
In a habeas corpus case, the Philippine Supreme Court upholds the
constitutionality of a provision allowing provincial governors to direct non-
Christian inhabitants to live on designated public lands, citing historical
treatment of indigenous people and the government's authority to promote the
general welfare and public interest.
Case Summary (G.R. No. 14078)
Case Background and Historical Treatment of Indigenous People
The case involves a habeas corpus case in which the Philippine Supreme Court
upholds the constitutionality of a provision allowing provincial governors to direct
non-Christian inhabitants to live on designated public lands.
The court provides a brief history of the treatment of indigenous people in the
Philippines, both before and after the acquisition of the Philippines by the United
States.
Various laws and decrees were enacted to improve the conditions of these
inhabitants, including the concentration of indigenous people in "reducciones" or
settlements.
Definition of "Non-Christian"
The term "non-Christian" is discussed and defined as referring to natives of the
Philippine Islands of a low grade of civilization, rather than having a religious
connotation.
The term is seen as relating to geographical area and the level of civilization of the
inhabitants.
Specific Case of the Manguianes Tribe
The specific case involves the Manguianes, a tribe in Mindoro, who are described as
being very low in culture and having considerable Negrito blood.
The Manguianes have not shown a desire for community life and have remained in a
primitive, semi-nomadic state.
Comparison to Treatment of American Indians
The court compares the treatment of non-Christian inhabitants in the Philippines to
the treatment of American Indians in the United States.
It mentions the policy of treating Indians as "in a state of pupilage" and the
government's role as a guardian and ward.
The court also references the power of Congress to regulate commerce with Indian
tribes.
Conclusion and Upholding of Provision
The court upholds the provision allowing provincial governors to direct non-
Christian inhabitants to live on designated public lands.
It emphasizes the government's authority to promote the general welfare and public
interest, as well as the historical treatment of indigenous people.
The court also mentions the need to balance conflicting solutions in order to
promote the public welfare.
Constitutional Arguments Raised by Petitioners
The case involves the constitutionality of Section 2145 of the Administrative Code of
the Philippines, which allows for the segregation and confinement of non-Christian
tribes in reservations.
The petitioners argue that the law violates their constitutional rights to religious
freedom, liberty, due process of law, equal protection of the laws, and protection
against slavery and involuntary servitude.
Historical Context of the Law and Interpretation of "Non-Christian"
The court examines the historical context of the law, noting that it was enacted
during the American colonial period when the government sought to civilize and
assimilate the non-Christian tribes.
The court finds that the term "non-Christian" refers to natives of the Philippines who
are of a low degree of civilization, rather than their religious beliefs.
Various government officials and documents are cited to support this interpretation.
Constitutional Arguments Addressed by the Court
The court rejects the argument that the law discriminates based on religious beliefs,
as the term "non-Christian" refers to civilization rather than religion.
The court finds that the law does not violate the rights to liberty, due process of law,
and equal protection of the laws, as it is a legitimate exercise of the police power to
promote the general welfare and protect the public interest.
The court notes that the law aims to improve the living conditions and education of
the non-Christian tribes, and to protect the public forests and prevent crimes and
depredations.
Thirteenth Amendment and Conclusion
The court considers the argument that the law violates the Thirteenth Amendment's
prohibition against slavery and involuntary servitude.
The court concludes that the confinement of the non-Christian tribes in reservations
does not constitute slavery or involuntary servitude, as it is for their own good and
the good of the country.
The court emphasizes that the government's policy is to guide the non-Christian
tribes towards civilization and make them useful citizens.
Upholding of Section 2145 and Dissenting Opinions
The court upholds the constitutionality of Section 2145 of the Administrative Code
and denies the petition for habeas corpus.
The court emphasizes the importance of the government's policy to promote the
advancement and unification of all the people of the Philippines.
The dissenting opinions argue that the Manguianes were being deprived of their
liberty without a hearing and that the law allowing for their confinement was
unconstitutional.
They emphasize the importance of individual rights and the potential for abuse of
power under the law.
