GR 14078 (1919) Petition for Writ of Habeas Corpus Rubi, Dabalos, et al. (Mangyans) vs.

. The Provincial Board of Mindoro Facts Mangyans of Mindoro were relocated to Sitio Tigbao on Lake Najuan (previously unoccupied public lands) by virtue of o Reso. No. 25 of the Provincial Board (Feb. 1, 1917) o EO No. 2 of the Provincial Governor Morente (Dec. 4, 1917), as approved by the Interior Secretary (Feb. 21, 1917) The particular action was premised on o Sec. 2145 of the Administrative Code sanctioning relocating nonChristians as the prerogative of the provincial government in the interest of law and order o Sec. 2759 penalizing those who refuse to be relocated thus, after due process Rubi and the Mangyans were petitioning for a writ of habeas corpus, that they may be freed from what they alleged to be an unlawful deprivation of liberty in the appointed reservation, and in behalf of a Doroteo Dabalos, who was being detained for having run away from the same

Issues 1) WON Sec. 2145 of the Admin. Code 1919 constituted an abdication of legislative power by the Philippines Legislature, and was therefore unconstitutional 2) WON Sec. 2145 discriminated on the basis of religious belief, and was therefore unconstitutional 3) WON the action against the Mangyans deprived them of liberty and property, and was thus violative of the constitutional guarantees of the same, without due process 4) WON the reconcentration delivered the Mangyans effectively to slavery and involuntary servitude, and was thus violative of the constitutional prohibition of the same 5) WON the action against the Mangyans constituted an unlawful use of the states police power Decision Petition for writ of habeas corpus was denied Rationale i. Sec. 2145 was a lawful delegation of power by the Legislature to the provincial government. It required that the power to relocate and reconcentrate citizens be exercised by the local executive with the approval of the Int. Sec., with checks in place to ensure that due process will be observed

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Sec. 2145 discriminated on the basis of the natives level of civilization rather than their religious status. The traditional term of non-Christian inhabitants has assumed this meaning from the Spanish to the American period of occupation, and had been retained only as a matter of convenience. The action of the provincial government of Mindoro did not deprive the Mangyans of liberty, properly understood. The court interpreted liberty in its civil rather than absolute form (liberty is not license); the liberty of a citizen is freedom within the bounds of the law to do what is acceptable and in pursuit of good objectives. This clashed with the Mangyans concept of natural freedom, the exercise of which brought them into conflict with the more advanced civilization spreading around them (ex. their nomadic lifestyle and caingin farming clashed with homestead farming). Relocation was intended for the good of the Mangyans and society at large. They were not deprived of due process since The law was reasonable It was enforced according to regular methods It applied to all of the same class The Mangyans were not enslaved. The relocation policy was in fact partly premised on the probability that the Mangyans would end up enslaved or exploited by wicked parties if they were permitted to continue their nomadic ways. In any event, they and their children were being provided instruction in civilization, instruction in formal knowledge, and health and other services befitting people of liberty. The action was a valid exercise of police powers by the government. It was in pursuit of the general welfare and was intended for the good of the Mangyans.