Case Digest (G.R. No. 135385) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioners Isagani Cruz and Cesar Europa, acting as private citizens and taxpayers, filed with this Court a petition for prohibition and mandamus assailing key provisions of Republic Act No. 8371 (the Indigenous Peoples Rights Act of 1997 or IPRA) and its Implementing Rules and Regulations. They contended that Sections 3(a) and 3(b) (defining the extent and coverage of ancestral domains and lands), Section 5 (recognizing ancestral domains as private but community property), Section 6 (defining the composition of ancestral domains and lands), Sections 7 and 8 (enumerating the ownership and disposition rights of indigenous cultural communities/indigenous peoples or ICCs/IPs), Section 57 (granting ICCs/IPs priority rights in the extraction or exploitation of natural resources), Section 58 (imposing environmental management responsibilities on ICCs/IPs), and Section 59 (requiring NCIP certification before issuance of concessions, leases or production-sharing agreements), unconstit Case Digest (G.R. No. 135385) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Appearance
- Petitioners: Isagani Cruz and Cesar Europa, citizens/taxpayers, seek writs of prohibition and mandamus to challenge constitutionality of provisions of R.A. 8371 (Indigenous Peoples Rights Act of 1997, “IPRA”) and its Implementing Rules and Regulations (IRR).
- Respondents:
- National Commission on Indigenous Peoples (NCIP) Chairperson and Commissioners – defend IPRA’s constitutionality.
- Secretary of the Department of Environment and Natural Resources (DENR) and Secretary of Budget and Management (DBM) – partially challenge IPRA’s grant of ownership over natural resources to indigenous peoples.
- Intervenors:
- Senator Juan Flavier et al. – support IPRA.
- Commission on Human Rights – support IPRA as parens patriae protection.
- Ikalahan IPs and Haribon Foundation – defend IPRA.
- Nature of the Petition
- Petitioners filed suit for prohibition and mandamus to:
- Declare invalid Sections 3, 5, 6, 7, 8, 52(i), 57, 58, 59, 63, 65, 66 of IPRA and related IRR provisions.
- Enjoin NCIP, DENR, DBM from implementing said provisions or disbursing funds therefor.
- Mandamus commanding DENR Secretary to perform constitutional duty to control and supervise natural resources.
- Grounds: IPRA allegedly infringes State ownership of public domain and natural resources under Article XII, Section 2 of the 1987 Constitution (Regalian doctrine) and violates due process and separation of powers.
- Proceedings and Deliberation
- Court required comments; solicited and received consolidated Comments from NCIP, DENR, DBM, and motions to intervene.
- Oral arguments heard April 13, 1999; memoranda filed thereafter.
- Initial vote: 7 members to dismiss petition, 7 to grant. Case redeliberated; tie 7–7.
- Result: Petition DISMISSED pursuant to Rule 56, Sec. 7, Rules of Civil Procedure (majority vote not obtained).
Issues:
- Does IPRA’s definition of ancestral domains and ancestral lands (Sec. 3(a), 3(b)) unlawfully deprive the State of ownership over lands of the public domain, contrary to Article XII, Section 2 of the Constitution?
- Do IPRA’s provisions recognizing communal ownership and granting rights of ownership and possession over ancestral domains and lands (Secs. 5, 6, 7, 8) exceed Congress’s constitutional mandate and violate the Regalian doctrine?
- Do Sections 57 and 58 of IPRA unlawfully confer on indigenous peoples ownership or exclusive control of natural resources within ancestral domains, displacing State ownership, control and supervision?
- Do Sections 51–53 and 59, vesting NCIP with exclusive authority to delineate ancestral domains/lands and requiring NCIP certification before any resource concession, unlawfully deprive other agencies of jurisdiction and violate separation of powers?
- Do Sections 63, 65 and 66, giving primacy to customary law in property and land‐dispute resolution, violate the due process and equal protection clauses by excluding non‐indigenous parties?
- Does Rule VII, Part II, Sec. 1 of the IRR, characterizing NCIP as an independent lateral agency under the Office of the President, infringe on the President’s power of control over the Executive Departments?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)