Case Digest (G.R. No. 223808)
Facts:
Heirs of Aida Pineda, represented by Ella Pineda Torcedo, v. Office of the President, Department of Environment and Natural Resources, and Heirs of Teofilo Pilando, Sr., G.R. No. 223808, April 26, 2023, Supreme Court Second Division, Leonen, SAJ., writing for the Court.In 1991, Aida Pineda applied for an ancestral land claim over a parcel in Baguio City (claimed area reported as 49,645 sq. m.). Pursuant to DENR Special Order No. 31, s. 1990, a Special Task Force surveyed the land (survey approved March 31, 1992) and, on June 24, 1993, the Department of Environment and Natural Resources issued four Certificates of Ancestral Land Claim (CALCs Bg-0032 to Bg-0035) in favor of Pineda covering 61,673 sq. m.
On August 22, 1996, the Heirs of Teofilo Pilando, Sr. filed a Petition for Annulment of the CALCs before the DENR, asserting a prior right traced to Pilando, who allegedly purchased the land in the 1950s, caused a survey approved in 1966 (GLRO SWO-129547), paid taxes since 1967, and thereby acquired private title or at least a right to a public land patent by longstanding possession. Pineda denied the Pilando claim and characterized it as fraudulent.
In a February 27, 2007 Decision (DENR Case No. 8319), the DENR ordered the recall of the CALCs in Pineda’s name and directed segregation of Pilando’s claim, explaining that the Special Task Force’s recommendations were not binding because they were issued in anticipation of the Indigenous Peoples’ Rights Act (IPRA, R.A. No. 8371) and that Pilando’s predecessors established a prior right as long-time occupants. The DENR’s dispositive paragraph recalled the CALCs and required the Pilando heirs to file a public land application within 60 days.
The Office of the President, through Executive Secretary Paquito N. Ochoa, Jr., in an March 30, 2011 Decision (O.P. Case No. 09‑C‑115), affirmed the DENR, holding that the 1993 CALCs had no legal basis prior to IPRA’s enactment and that, even after enactment, Baguio City was excluded from IPRA by Section 78, R.A. No. 8371; the Office of the President also recognized the Pilando line’s right to a government grant by operation of law and found the Special Task Force lacked authority to issue the CALCs.
The Heirs of Pineda sought relief in the Court of Appeals via a petition for review. In a June 23, 2015 Decision (CA-G.R. SP No. 128152), the Court of Appeals affirmed the Office of the President and the DENR, reasoning that CALCs were provisional, did not mature into title within Baguio City (excluded under Section 78), and that the DENR had primary administrative jurisdiction at the time the cancellation petition was filed (pre‑IPRA). The Court of Appeals accorded respect to DENR’s factual findings and denied the petition in a March 2, 2016 Resolution denying reconsideration.
On April 29, 2016, the Heirs of Pineda filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court in the Supreme Court, challenging the Court of...(Pro-only)
Issues:
- Did the Court of Appeals err in affirming the DENR and Office of the President decisions recalling the Certificates of Ancestral Land Claim issued in favor of petit...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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