Case Digest (G.R. No. 160890)
Facts:
In Republic of the Philippines v. National Commission on Indigenous Peoples, G.R. No. 208480 (Decided November 30, 2020), the Republic of the Philippines, represented by the Office of the Solicitor General, petitioned this Court for review under Rule 45 to annul and set aside NCIP Resolution No. 107-2010-AL and NCIP Resolution No. 108-2010-AL (both dated November 10, 2010) and all subsequent Transfer Certificates of Title (TCTs) that stemmed from Certificates of Ancestral Land Title (CALT) covering properties within the Baguio City Townsite Reservation. The CALTs had been issued in favor of the heirs of Cosen Piraso and the heirs of Josephine Molintas Abanag, who claimed native title over certain parcels of land in Session Road and other areas of Baguio City under Republic Act No. 8371 (IPRA) and Article XII, Section 5 of the 1987 Constitution. The land registration authority thereafter issued corresponding TCTs. The petition was first denied by the Court of Appeals in CA-G.R. SCase Digest (G.R. No. 160890)
Facts:
- Parties and Case Background
- The Republic of the Philippines (Petitioner), through the Office of the Solicitor General, filed a Petition for Review under Rule 45 against:
- National Commission on Indigenous Peoples (NCIP) – public respondent
- Register of Deeds of Baguio City and Land Registration Authority (LRA) – public respondents
- Heirs of Cosen Piraso and heirs of Josephine Molintas Abanag, Marion T. Pool, Joan L. Gorio, and Virginia C. Gao-an – private respondents
- The petition assailed NCIP Resolution Nos. 107-2010-AL and 108-2010-AL (both dated November 10, 2010) which:
- Recognized ancestral land rights of the Piraso and Abanag clans over parcels in the Baguio City townsite reservation under RA 8371 (IPRA)
- Directed the issuance of eight (8) and twenty-eight (28) Certificates of Ancestral Land Title (CALT), respectively
- Resulted in corresponding Transfer Certificates of Title (TCTs) by the LRA
- Proceedings Below
- NCIP Proceedings
- Piraso petition: Showed unbroken occupation for 120 years, genealogy, customary use; NCIP granted eight CALTs under Rés. 107-2010-AL
- Abanag petition: Demonstrated descent from Ibaloi ancestor, ocular inspection, rituals, tax receipts; NCIP granted twenty-eight CALTs under Rés. 108-2010-AL
- Court of Appeals Decision (Jan. 15, 2013)
- Denied Republic’s Petition for Certiorari, Prohibition, and Mandamus; refused injunctive prayers as moot
- Held IPRA applies to Baguio City and affirmed NCIP Rés. 107-2010-AL and 108-2010-AL
Issues:
- Coverage of IPRA
- Are lands within Baguio City and the Baguio Townsite Reservation subject to RA 8371 despite Section 78’s special provision?
- NCIP Jurisdiction
- Did the NCIP have authority to issue CALTs/CADTs over townsite reservation lands without congressional reclassification?
- Validity of NCIP Resolutions
- Are Rés. 107-2010-AL and 108-2010-AL valid under the Constitution, IPRA, and jurisprudence?
- Conversion into Torrens Titles
- Can CALTs lawfully be converted into Torrens TCTs absent specific statutory authorization?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)