Case Digest (G.R. No. 209449)
Facts:
This case involves the Republic of the Philippines as petitioner and the National Commission on Indigenous Peoples (NCIP), Register of Deeds of Baguio City, Land Registration Authority, heirs of Lauro Carantes, Dimson Manila, Inc., Joan L. Gorio, and unidentified parties as respondents. The issue arose from claims filed by the heirs of Lauro Carantes for Certificates of Ancestral Land Titles over properties within Baguio City, which were initially granted by the Court of Appeals but later challenged before the Supreme Court. The Court of Appeals ruled in favor of the heirs of Carantes, but the Supreme Court, in its July 11, 2023 decision, reversed this, stating that Baguio City is exempt from the coverage of the Indigenous Peoples' Rights Act (Republic Act No. 8371 or IPRA) except for native title, which recognizes ownership since time immemorial when indigenous peoples are in actual possession of the land. The heirs of Carantes failed to prove such possession. Respondents filedCase Digest (G.R. No. 209449)
Facts:
- Parties and Case Background
- The Republic of the Philippines filed a petition against the National Commission on Indigenous Peoples (NCIP), Register of Deeds of Baguio City, Land Registration Authority, heirs of Lauro Carantes, Dimson Manila, Inc., Joan L. Gorio, and certain unnamed parties.
- The case concerns the claim of the heirs of Lauro Carantes to ancestral land titles within Baguio City, which the NCIP had recognized.
- Lower Court and Court of Appeals Decisions
- The Court of Appeals initially ruled in favor of the heirs of Lauro Carantes, allowing the issuance of Certificates of Ancestral Land Titles (CALT).
- The Republic of the Philippines filed a petition for review on certiorari, challenging this decision, arguing that Baguio City is exempt from the Indigenous Peoples' Rights Act (IPRA) coverage as per Section 78 of the law.
- Supreme Court Decision and Subsequent Motions
- On July 11, 2023, the Supreme Court en banc granted the Petition for Review, setting aside the Court of Appeals' decision and resolution. It held that:
- Baguio City is exempt from the coverage of the IPRA, except for native title to land, meaning ownership since time immemorial where indigenous peoples are still in actual possession.
- Certificates of Ancestral Land Titles cannot be issued in favor of the heirs of Lauro Carantes as they failed to prove actual occupation and possession since time immemorial.
- Respondents filed Motions for Reconsideration raising issues of due process, applicability of IPRA to Baguio City, and proof of possession.
Issues:
- Whether Baguio City is exempt from the coverage of IPRA under Section 78 of the law.
- Whether the heirs of Lauro Carantes have sufficiently established their occupation and possession of the claimed ancestral land since time immemorial to claim native title.
- Whether Certificates of Ancestral Land Titles can be validly issued to the heirs of Lauro Carantes.
- Whether the petitioner was deprived of due process in the recognition proceedings of the ancestral land claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)