Title
City Mayor of Baguio vs. Masweng
Case
G.R. No. 165003
Decision Date
Feb 2, 2010
Ibaloi tribe's ancestral land claim in Baguio overlaps with Baguio Dairy Farm; NCIP's injunction against demolition reversed by SC due to lack of jurisdiction and legal right.

Case Summary (G.R. No. 165003)

Background and Jurisdiction

The case revolves around the respondents' ancestral land claims dating back to 1920 when their ancestors were granted a survey plan approved by the Director of Lands. The specific land in question overlaps with the Baguio Dairy Farm, established as a government reservation under the supervision of the Department of Agriculture. The heirs of Judith Cariao and the other respondents filed a petition with the NCIP for validation of their ancestral land claims, which prompted a Demolition Order from the office of the mayor due to unauthorized constructions in the area.

NCIP Proceedings and the Injunction

On June 29, 2003, the respondents sought an injunction from the NCIP to block the enforcement of Demolition Order No. 17, which targeted unauthorized structures within the Baguio Dairy Farm. The NCIP regional hearing officer, Atty. Brain Masweng, initially granted the respondents a temporary restraining order (TRO) and subsequently a writ of preliminary injunction. Petitioners’ motion for reconsideration against this ruling was denied, leading to an appeal to the Court of Appeals (CA).

Issues Raised by Petitioners

The petitioners contended that injunctions, as original actions, fall under the jurisdiction of regular courts, and that the NCIP could only issue such remedies in the context of ongoing cases. They asserted that the issuance of the injunction lacked factual and legal basis and, therefore, was invalid.

Precedential Case Consideration

The petitioners relied on a previous ruling in "City Government of Baguio City v. Atty. Masweng”, where the Supreme Court upheld that the NCIP possesses the authority to issue TROs and injunctions when the main action concerns injunction, affirming the ability of affected parties to seek preliminary relief against actions causing grave harm.

Analysis of Rights and Legal Principles

The Court found that the respondents’ claims to the disputed land were based on historical possession and a survey plan, but that their rights remained tentative and were not the established legal rights necessary to warrant a preliminary injunction. The structures in question were reportedly built without the requisite permits, leading to the conclusion that the pr

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