CONSTITUTIONAL LIMITATIONS
2. EQUAL PROTECTION OF THE LAWS
Tan v. Del Rosario, supra.
       The said law is not arbitrary; it is germane to the purpose of the law and; applies to all things
        of equal conditions and of same class.
       It is neither violative of equal protection clause due to the existence of substantial difference
        between one who practice his profession alone and one who is engaged to proprietorship.
       Further, the SC said that RA 7496 is just an amendatory provision of the code of taxpayers
        where it classifies taxpayers in to four main groups: Individuals, Corporations, Estate under
        Judicial Settlement and Irrevocable Trust. The court would have appreciated the contention
        of the petitioner if RA 7496 was an independent law. But since it is attached to a law that has
        already classified taxpayers, there is no violation of equal protection clause.