Case Summary (G.R. No. 217837)
Applicable Law
The case primarily references provisions from the 1987 Philippine Constitution, notably Article XII, Section 2, governing ownership of public lands and ancestral domains, as well as pertinent laws such as Republic Act No. 8371 (Indigenous Peoples' Rights Act of 1997).
Background and Factual Context
The petitioners claim to be descendants of early settlers in Calauit Island, asserting they were forcibly relocated to Halsey and Burabod by the government due to the establishment of a wildlife sanctuary. Allegations of harassment during relocation surfaced, along with claims that the resettlement areas were unsuitable for habitation. The government had promised agricultural lots and compensation for improvements on vacated properties but failed to fulfill these obligations adequately.
Government Actions and Legal Instruments
In 1976, Presidential Proclamation No. 1578 designated Calauit as a Game Preserve and Wildlife Sanctuary, limiting human activities and occupancy. Subsequently, resettlement terms were formalized in individual Resettlement Agreements, wherein the settlers waived claims to the land in exchange for relocation allowances and land elsewhere. After the Marcos administration, a movement to reclaim rights over Calauit emerged, culminating in a fact-finding commission's recommendation to revoke the proclamation due to violations of settlers' rights.
Proceedings and Judicial Outcomes
The initial suit, filed by the Republic against the petitioners, aimed to reclaim possession of Calauit, claiming the petitioners had unlawfully reoccupied the land despite waiving their rights. The Regional Trial Court ruled in favor of the Republic, upholding the Resettlement Agreements and ordering the petitioners to vacate Calauit, highlighting national interest in conserving the area as a wildlife sanctuary. The Court of Appeals affirmed this decision.
Petitioners' Claims on Appeal
The petitioners challenged the lower court's rulings, arguing their right to ownership based on longtime occupation and the allegedly unlawful nature of the Resettlement Agreements, which they claimed were signed under duress and deceit. They contested the admissibility of the Resettlement Agreements and requested damages.
Supreme Court Ruling and Justiciability
The Supreme Court ultimately found the case moot due to the issuance of a Certificate of Ancestral Domain Title (CADT) in favor of the Tagbanua Indigenous Cultural Community in 2008, which recognized their rights over the ancestral domain, including Calauit Island. The Court determined that the presence of the CADT superseded earlier ag
...continue readingCase Syllabus (G.R. No. 217837)
Background of the Case
- The case revolves around a petition for review on certiorari filed by numerous petitioners, namely Aurellano Agnes and others, against the Republic of the Philippines.
- The central issue pertains to the legality of the Resettlement Agreements signed by the petitioners, who claim ancestral rights over Calauit Island, which has been declared a Game Preserve and Wildlife Sanctuary by Proclamation No. 1578, signed by then-President Ferdinand E. Marcos in 1976.
- The petitioners assert that they are descendants of early settlers of Calauit Island and have a legitimate claim to the lands they occupied prior to their relocation in 1977.
Historical Context
- Calauit Island, encompassing 3,600 hectares, is part of the Calamianes Island group in Palawan, Philippines.
- The petitioners were part of the "Balik Calauit Movement," which sought to reclaim lands they had occupied prior to government relocation due to the establishment of the Calauit Game Preserve.
- In 1973, the Bureau of Lands began surveying Calauit, initially promising titling for the settlers' landholdings.
- The government's narrative changed in 1975, claiming the area would serve as a zoo, leading to the forced relocation of the settlers to Halsey and Burabod, which they allege were inadequate for habitation and agriculture.
Legal Proceedings and Agreements
- The settlers signed individual Resettlement Agreements under duress, relinquishing their rights to the land in exchange for promised agricultural lots and financial compensation for improvements m