Case Digest (G.R. No. 192112)
Facts:
The petitioners, heirs of the 133 awardees of a 1957 Amended Decision, challenged the National Commission on Indigenous Peoples (NCIP) Decision dated February 18, 2010 in NCIP Case No. 002-2009, which reversed the Regional Hearing Officer's (RHO) July 17, 2009 dismissal and issued a permanent injunction restraining implementation of a DARAB writ of execution and notice to vacate affecting land in Malalag, Davao del Sur; the private respondents had filed the NCIP complaint on February 20, 2009 and the RHO had earlier issued a TRO on February 24, 2009. Petitioners filed a petition for certiorari and prohibition before the Court alleging grave abuse of discretion, and the Court partly granted the petition, nullified and set aside the NCIP Decision, and dismissed the private respondents' complaint for lack of jurisdiction.
Issues:
- Did the NCIP commit grave abuse of discretion in finding that the private respondents were not guilty of forum-shopping?
- Did the NCIP act beyond its jurisdiction by treating the passage of the IPRA and issuance of a CALT as supervening events that rendered prior executory awards unenforceable?
- Was the NCIP ousted of jurisdiction by filing a petition against the DAR/DARAB in CA-G.R. SP. No. 01377?
- Did the NCIP act in excess of jurisdiction when it granted injunctive relief restraining the DARAB writ of execution?
Ruling:
The Court partly granted the petition and nullified and set aside the NCIP Decision dated February 18, 2010. The Court held that the NCIP had no jurisdiction to entertain the private respondents' complaint and accordingly dismissed the complaint for lack of jurisdiction; the Court nonetheless declined to decide the parties' competing ownership claims and refused to enjoin other tribunals from acting on related matters.
Ratio:
The Court applied the interpretation in Unduran v. Aberasturi construing Section 66 of the IPRA to limit NCIP jurisdiction to claims and disputes arising between or among parties who belong to the same ICC/IP, subject to exhaustion of customary remedies and certification by the Council of Elders/Leaders; jurisdiction is determined by the allegations in the complaint and, because the parties here do not belong to the same ICC/IP, the case falls to the proper courts, not the NCIP. Although the Court noted petitioners' procedural lapses (failure to file a motion for reconsideration and direct recourse to the Court instead of the Court of Appeals), it resolved the jurisdictional question on the merits and confined its decision to the NCIP's grant of injunctive relief.
Doctrine:
- Section 66 of the IPRA, as construed in Unduran v. Aberasturi, limits NCIP jurisdiction to disputes between or among parties belonging to the same ICC/IP.
- When parties belong to different ICCs/IPs or one party is a non-ICC/IP, the proper courts of justice have jurisdiction over the dispute.
- Decisions of the NCIP are appealable to the Court of Appeals under Section 67 of the IPRA.
- A petition for certiorari under Rule 65, Rules of Court, is unavailable when an adequate appeal remedy exists and a motion for reconsideration was not first pursued.
- The Supreme Court will ordinarily decline direct original relief where the doctrine of hierarchy of courts prescribes lower forums, absent special and important reasons.