G.R. No. 207851 - Naval vs. Commission on Elections

In 1991, Aida Pineda filed an application for an ancestral land claim over a parcel in Baguio City, amounting to 49,645 square meters.
This application was made pursuant to DENR Special Order No. 31, series of 1990, which established a Special Task Force to identify, evaluate, and delineate ancestral land claims in the Cordillera Administrative Region.
Between November 12 and 19, 1991, a survey of the land was conducted and later approved by the Regional Surveys Division of the DENR on March 31, 1992.
The approved survey identified the area as part of Lot No. 1, PSU-223647, previously connected with Teofilo Pilando through Civil Res. Case 1, GLRO Rec. No. 211.

On June 24, 1993, based on the Special Task Force’s recommendations, the DENR issued four Certificates of Ancestral Land Claim (CALCs) – Bg-0032, Bg-0033, Bg-0034, and Bg-0035 – covering an expanded area of 61,673 square meters in the residential section “J” of Loakan, Baguio City, in favor of Pineda.
The expansion of the claimed area from 49,645 square meters to 61,673 square meters later raised issues concerning the proper delineation and extent of the ancestral lands.

On August 22, 1996, the Heirs of Teofilo Pilando, Sr. (respondents) filed a Petition for Annulment of the CALCs, asserting a prior right over the land based on their lineage and continued occupation.
The respondents claimed that their predecessor, Teofilo Pilando, a member of the Kankanaey tribe, had acquired title and possession of the land through purchase and subsequent improvements dating back to the mid-20th century.
They supported their claim with evidence of earlier surveys, a Bureau of Lands approval in 1966, and longstanding tax declarations indicating possession.

On February 27, 2007, the DENR ordered the recall of the CALCs issued in favor of Pineda and segregated the claim of the Heirs of Pilando, citing that the Special Task Force’s actions were preparatory only and not binding, especially in light of the forthcoming Indigenous Peoples’ Rights Act (IPRA).
In its March 30, 2011 Decision, the Office of the President affirmed the DENR’s ruling, holding that the CALCs issued in 1993 had no legal basis since Baguio City was expressly excluded from the coverage of IPRA under Section 78 of Republic Act No. 8371.
The Court of Appeals subsequently affirmed the decisions of both the Office of the President and the DENR, emphasizing that the CALCs were provisional, and determining that jurisdiction over the petition for cancellation belonged primarily to the DENR.

Represented by Ella Pineda Torcedo, the petitioners (Heirs of Aida Pineda) filed a petition contesting the Court of Appeals’ decision.
Petitioners argued that the exclusion of Baguio City from the IPRA did not negate their native title over the land and claimed that they had sufficiently demonstrated continuous possession and ownership as far back as memory reaches.
They contended that the appellate court’s reliance on the city’s charter and the administrative decisions violated constitutional guarantees and overlooked evidence of their prior rights.

The Indigenous Peoples’ Rights Act (IPRA) and Republic Act No. 8371 (with Section 78) are central to the case, highlighting that Baguio City is governed by its charter rather than IPRA, except for prior land rights acquired through judicial, administrative, or other processes before IPRA’s effectivity.
Precedents such as City Government of Baguio v. Atty. Masweng and cases involving the conversion of CALCs to Certificates of Ancestral Land Title (CALT) underscore that the issuance of a CALC does not equate to a conclusive title.
Historical practices concerning land registration, including references to Act No. 926 and related administrative orders, provide the backdrop for understanding native title claims and the necessity of proper registration within prescribed periods.

Whether the Court of Appeals erred in affirming the decisions of the DENR and the Office of the President concerning the recall of the Certificates of Ancestral Land Claim issued in favor of petitioners.

Does the exemption provided by Section 78 of the Indigenous Peoples’ Rights Act, which limits its application in Baguio City, preclude the petitioners from establishing native title over the disputed land?
Whether the issuance of a CALC automatically confers ownership or an irrefutable title, or if it remains provisional until converted into a CALT.
Whether the petitioners’ evidence of continuous possession and ownership—coupled with the historical and administrative background—sufficiently established their prior rights despite the area expansion and the legal framework adopted by the respondents.
Whether the fact findings of the Court of Appeals, supported by substantial evidence regarding the role of the DENR and the Office of the President, warrant deference in a petition for review on certiorari that only permits questions of law.