BRITISH AMERICAN TABACCO VS.

CAMACHO

FACTS:
The classification freeze provision was inserted in the law for reasons of practicality and
expediency. That is, since a new brand was not yet in existence at the time of the passage
of RA 8240, then Congress needed a uniform mechanism to fix the tax bracket of a new
brand. The current net retail price, similar to what was used to classify the brands under
Annex D as of October 1, 1996, was thus the logical and practical choice. Further, with the
amendments introduced by RA 9334, the freezing of the tax classifications now expressly
applies not just to Annex D brands but to newer brands introduced after the effectivity of
RA 8240 on January 1, 1997 and any new brand that will be introduced in the future.

Petitioner argues that the classification freeze provision violates the equal protection and
uniformity of taxation clauses because Annex D brands are taxed based on their 1996 net
retail prices while new brands are taxed based on their present day net retail prices.

Petitioner asserts that the assailed provisions accord a special or privileged status to
Annex D brands while at the same time discriminate against other brands.

ISSUE:
Whether or not the classification freeze provision violates the equal protection clause.

RULING:
These contentions are without merit and a rehash of petitioners previous arguments
before this Court. As held in the assailed Decision, the instant case neither involves a
suspect classification nor impinges on a fundamental right. Consequently, the rational
basis test was properly applied to gauge the constitutionality of the assailed law in the face
of an equal protection challenge. It has been held that in the areas of social and economic
policy, a statutory classification that neither proceeds along suspect lines nor infringes
constitutional rights must be upheld against equal protection challenge if there is any
reasonably conceivable state of facts that could provide a rational basis for the
classification. Under the rational basis test, it is sufficient that the legislative classification
is rationally related to achieving some legitimate State interest.

At any rate, petitioners real disagreement lies with the legitimate State interests.Although
it concedes that the Court utilized the rationality test and that the classification freeze
provision was necessitated by several legitimate State interests, however, it refuses to
accept the justifications given by Congress for the classification freeze provision. As we
elucidated in our August 20, 2008 Decision, this line of argumentation revolves around
the wisdom and expediency of the assailed law which we cannot inquire into, much less
overrule. Equal protection is not a license for courts to judge the wisdom, fairness, or logic
of legislative choices. We reiterate, therefore, that petitioners remedy is with Congress
and not this Court.