Case Digest (G.R. No. 181284)
Facts:
Petitioners, mostly members of the Miarayon, Lapok, Lirongan, Talaandig Tribal Association (MILALITTRA), except Mark Brazil and Nestor Macapayag, claimed ancestral occupancy of lands in Barangay Miarayon, Talakag, Bukidnon; respondents, represented by Ramon Aberasturi, asserted ownership of an unregistered agricultural parcel (Lot No. 7367 Cad 630‑D, 105.7361 hectares) said to lie within the Talaandig CADT. Respondents filed an original complaint for accion reivindicatoria before the RTC on March 3, 2004 and later amended it to a complaint for injunction and damages; the RTC issued an order on February 14, 2005 denying referral to the NCIP, declaring most petitioners in default and granting preliminary injunction; the Court of Appeals affirmed (Aug. 17, 2006) with modification (lifting defaults) and denied reconsideration (July 4, 2007), prompting this petition for review on certiorari to the Supreme Court (decision Oct. 20, 2015).
Issues:
- Does the RTC lack jurisdiction over the amended complaint for injunction because the disputed land lies within the Talaandig ancestral domain covered by a CADT?
- Was the amendment of respondents' complaint from accion reivindicatoria to one for injunction a device to oust NCIP jurisdiction and therefore invalid?
- Did the Court of Appeals err in holding that jurisdiction is to be determined by the allegations of the complaint despite existence of a CADT and subsequent pleadings showing ancestral‑domain issues?
Ruling:
The petition was DENIED and the Court of Appeals Decision dated August 17, 2006 and Resolution dated July 4, 2007 were AFFIRMED. The Supreme Court held that the RTC properly exercised jurisdiction over the amended complaint because, on its face, the pleadings stated causes of action cognizable by the RTC. The Court also ruled that the NCIP’s statutory jurisdiction under Section 66 of the IPRA is limited as spelled out in the opinion and that certain NCIP rules expanding that jurisdiction were invalid to the extent of the expansion.
Ratio:
Jurisdiction is conferred by law and is determined by the allegations in the complaint; the character of the relief and the ultimate facts alleged control whether a matter is for the courts or for the NCIP. Under B.P. 129, Sec. 19, the RTC has original jurisdiction over civil actions incapable of pecuniary estimation and actions involving title or possession of real property above statutory thresholds. Section 66, IPRA grants the NCIP jurisdiction over claims and disputes involving rights of ICCs/IPs only when parties have first exhausted remedies under their customary laws and complied with the council certification requirement, which, in effect, limits NCIP jurisdiction to disputes between or among members of the same ICC/IP; administrative rules that expand statutory jurisdiction conflict with the enabling statute and are void.
Doctrine:
- Jurisdiction over a case is determined by the allegations in the complaint and the character of the relief sought, not by subsequent or extraneous pleadings.
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