G.R. No. 156022 - Agnes vs. Republic

Calauit Island is a 3,600-hectare island in the Calamianes group, Province of Palawan, which later became the subject of a series of governmental actions.
Over 250 families, known collectively as the Balik Calauit Movement, claim to be successors of the early settlers who occupied the island.
The settlers assert title either through a predecessor’s title acquired under Act No. 926 or by unbroken, continuous, exclusive, and notorious possession and cultivation of the land until their relocation in 1977.

In 1973, the Bureau of Lands initiated a survey of Calauit, during which surveyors encountered resistance from the settlers.
Initially, settlers were informed that the survey was for titling purposes and for allotting lands to incoming settlers from Busuanga who would be relocated for the Yulo King Ranch project.
By 1975, settlers were told that titling would not proceed because the island was to be transformed into a zoo for rare and exotic animals and that they would instead be relocated to supposedly more favorable areas (Halsey and Burabod in Culion) where complete government services would be provided.

The relocation proposal materialized through individual Resettlement Agreements, which stipulated:

In exchange for vacating their areas, settlers would receive an agricultural lot and payment for the improvements on their properties as determined by individualized appraisal sheets.
Settlers were to agree to relocate to resettlement areas, totally relinquish any claim over their original lands, and vacate the premises upon receipt of partial appraised payment—with the balance payable upon complete evacuation.

The agreements were executed under conditions of alleged intimidation, deceit, and harassment by government forces, notably the Philippine Constabulary.

On August 31, 1976, President Ferdinand E. Marcos issued Presidential Proclamation No. 1578, designating Calauit as a Game Preserve and Wildlife Sanctuary, effectively withdrawing the island from sale or settlement.
The Department of Natural Resources (later DENR) established the Calauit Special Project (CSP) to manage the sanctuary, and in 1977, President Marcos issued Proclamation No. 1626, opening portions of the Culion Leper Colony Reservation (Halsey and Burabod) for resettlement.

Petitioners, alongside other settlers, contested their forced relocation and engaged the Philippine Commission on Human Rights (PCHR), which conducted fact-finding and recommended both the repeal of Proclamation No. 1578 for violating their rights and the immediate return of the settlers to Calauit.
Despite initial attempts to return to the island (with some success in June 1987), a subsequently issued order by then DNR Secretary Fulgencio Factoran compelled them back to the designated resettlement zones.
A prior petition for certiorari (G.R. No. 80034) filed by some settlers was dismissed on the ground that the issues were primarily factual and for trial in the lower courts.

In Civil Case No. 2262 filed by the Republic of the Philippines against the petitioners, the RTC of Puerto Princesa City rendered its Decision on February 23, 1994.

The RTC ordered petitioners (with certain exceptions) to vacate the areas they occupied in Calauit Island.
It mandated that the Republic, through the DENR Secretary, secure alternative relocation sites within six months.

The RTC held that the Resettlement Agreements, though lacking notarization, were deemed public documents and that any vices of consent would merely render them voidable rather than void—further noting that the period to challenge them had long prescribed.
The RTC reasoned that petitioners, dissatisfied with the resettlement areas, should claim compensation for the fair value of their improvements rather than unilaterally rescind the agreements and reoccupy Calauit, seen as a wildlife sanctuary.

The petitioners appealed the RTC Decision (CA-G.R. CV No. 46222), contending various errors regarding ownership claims and contractual breaches.
On April 24, 2002, the Court of Appeals affirmed the RTC’s ruling, emphasizing:

The public domain status of Calauit, as asserted by the 1987 Constitution, which vests title to lands not alienated into the State.
The necessity of a government’s “positive act” to reclassify public lands into alienable disposable lands, thereby nullifying the petitioners’ possession claims.

Multiple motions for reconsideration were filed, and despite procedural issues and delayed filings, the Supreme Court eventually heard the Petition for Review on Certiorari, raising several assignments of error.
Amid these proceedings, on March 25, 2008, the National Commission on Indigenous Peoples (NCIP) issued a Certificate of Ancestral Domain Title (CADT) in favor of the Tagbanua Indigenous Cultural Community, covering Calauit and surrounding areas.
The issuance of the CADT significantly altered the legal landscape, as it affirmed the rights of the indigenous community over Calauit, thereby coloring the occupation of the petitioners with a semblance of state-sanctioned authority and rendering the central issues moot.

Whether the Resettlement Agreements, allegedly procured through intimidation, misrepresentation, and fraud, are valid and enforceable.
Whether the alleged vices of consent should render these agreements void or merely voidable, and if the applicable judicial prescriptive period precludes such challenges.

Whether the government, under Presidential Proclamation No. 1578, is justified in compelling the petitioners to vacate Calauit despite their longstanding occupation.
The extent to which the contractual obligations in the Resettlement Agreements bind the petitioners to relocate.

Whether the petitioners can assert a perfected claim of ownership over Calauit, given the presumption that public lands belong to the State until formally alienated.
The evidentiary sufficiency regarding tax declarations, historical possession, and certificates of title in establishing private ownership.

Whether the issuance of the CADT in favor of the Tagbanua Indigenous Cultural Community has rendered the issues discussed—the validity of the Resettlement Agreements and the right to remain on Calauit—moot and academic.
The implications of the CADT for the petitioners’ individual claims to land title and their continued occupation.

Whether the lower courts erred in admitting unnotarized Resettlement Agreements without proper authentication or witness testimony.
Whether the trial and appellate courts committed reversible errors in applying the rules of evidence and in the factual findings regarding government actions and settler responses.