Case Summary (A.C. No. 13911)
Factual Background
The petitioners are recognized members of the Ibaloi indigenous people who assert ancestral ownership and possession of the subject land from time immemorial. Petitioners alleged that respondents undertook earthmoving and bulldozing operations on the subject land that destroyed trees, plants, and other resources. Petitioners stated that their petition for the identification, delineation and recognition of ancestral claim and issuance of Certificate of Ancestral Land Titles was pending before the National Commission on Indigenous Peoples (NCIP). Petitioners also alleged violations of the Environmental Compliance Certificate issued to respondents and violations of PD 1586, and sought an immediate Environmental Protection Order and other reliefs.
Commencement and Nature of the Action
Petitioners filed Environmental Case No. 8548-R entitled “Enforcement/Violations of the Provisions of the Indigenous Peoples Rights Act (IPRA); PD 1586; and Other Pertinent Laws with Prayer for the Issuance of Environmental Protection Order and/or Writ of Preliminary Mandatory/Prohibitory Injunction, and Writ of Mandamus.” The complaint alleged environmental violations arising from respondents’ allegedly destructive earthmoving activities and sought, among others, an ex parte 72-hour Environmental Protection Order, injunctive relief, recognition of petitioners’ rights as IPs to the ancestral land, restoration of denuded areas, and compensation for damaged resources.
Trial Court Proceedings
The RTC, sitting as an environmental court, dismissed the complaint for lack of jurisdiction on March 2, 2017. The trial court reasoned that formal recognition of petitioners’ ancestral domain rights and issuance of CADTs/CALTs fell within the exclusive jurisdiction of the NCIP under Section 11 of the IPRA, and that petitioners’ principal relief amounted to a claim of ownership that rendered them not real parties in interest under Section 4, Rule 2 of A.M. No. 09-6-8-SC. The RTC concluded that petitioners’ asserted rights remained to be established and that the complaint was therefore premature. The RTC denied petitioners’ motion for reconsideration on April 3, 2017.
Parties’ Contentions on Review
Petitioners contended that the NCIP lacked jurisdiction because respondents were not members of the same ICC/IP and that the RTC, not the NCIP, therefore had jurisdiction. Petitioners emphasized that they were not seeking issuance of CALTs/CADTs in the present action but were seeking protection of their environmental rights under the IPRA and PD 1586. Respondent Baguio Properties, Inc. asserted ownership over the subject land and characterized the complaint as a collateral attack on its Torrens titles.
Issue Presented
The narrow issue before the Supreme Court was whether the court a quo’s outright dismissal of Environmental Case No. 8548-R for lack of jurisdiction was proper.
The Court’s Disposition
The Supreme Court granted the petition, nullified and set aside the assailed RTC orders dated March 2, 2017 and April 3, 2017, and reinstated Environmental Case No. 8548-R for proper disposition.
Jurisdictional Framework Applied
The Court recapitulated that jurisdiction is determined by the allegations in the complaint and the character of the relief sought, citing Unduran, et al. v. Aberasturi, et al. and other authorities to the effect that jurisdiction, once vested by the complaint, remains regardless of the plaintiff’s ultimate entitlement to relief. The Court examined Section 66 of the IPRA, which vests the NCIP with jurisdiction over claims and disputes involving rights of ICCs/IPs, and reiterated the delimitation in Unduran that the NCIP’s jurisdiction applies only when the dispute arises between or among parties belonging to the same ICC/IP and when remedies under customary law have been exhausted.
Why the NCIP Lacked Exclusive Jurisdiction
The Court held that the court a quo erred in treating the matter as solely within the NCIP’s domain because respondents are non-ICC/IP members. The Court explained that the NCIP has no authority to decide controversies involving non-ICCs/IPs and that disputes between ICCs/IPs and non-ICCs/IPs fall within the jurisdiction of the regular courts of justice. Consequently, the subject controversy, involving alleged environmental harms caused by non-ICC/IP respondents, could not be relegated exclusively to the NCIP.
Nature of the Claim and Proper Forum
The Court found that the complaint was not an action for issuance of CALTs/CADTs nor a bare claim of ownership. Petitioners expressly averred that their pending petition for CALTs before the NCIP did not foreclose their present cause of action, which was grounded on respondents’ earthmoving activities and alleged violations of environmental law and the ECC. The Court determined that these allegations constituted an environmental cause of action within the jurisdiction of the RTC sitting as a special environmental court under AO No. 23-2008, BP 129, and A.M. No. 09-6-8-SC.
Locus Standi of Petitioners
The Court rejected the RTC’s conclusion that petitioners lacke
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Case Syllabus (A.C. No. 13911)
Parties and Procedural Posture
- Heirs of Tunged namely: Rosita Yaris-Liwan, Virgie S. Atin-An, Beltran P. Saingan, Mabel P. Daling, Monica Y. Domingo, and Elizabeth Q. Pinono, petitioners, are recognized Indigenous People members of the Ibaloi tribe and claimed heirs of Tunged.
- Sta. Lucia Realty and Development, Inc. and Baguio Properties, Inc., respondents, were alleged operators and claimed owners or managers of portions of the subject land.
- Petitioners filed Environmental Case No. 8548-R for enforcement/violations of the provisions of the Indigenous Peoples Rights Act (IPRA) (Republic Act No. 8371), PD No. 1586, and other pertinent laws with prayers for an Environmental Protection Order and writs of injunction and mandamus.
- The Regional Trial Court of Baguio City, Branch V, dismissed the case for lack of jurisdiction by Order dated March 2, 2017, and denied a motion for reconsideration by Order dated April 3, 2017.
- Petitioners filed a Petition for Review on Certiorari under Rule 45, Rules of Court, assailing both assailed RTC orders before the Court.
Key Factual Allegations
- Petitioners alleged continuous occupation and ownership of the subject property by virtue of native title since at least 1924 and asserted that their possession was proven by testimonial and documentary evidence.
- Petitioners alleged that respondents conducted earthmoving activities, demolitions, and bulldozing which destroyed trees, sayote plants, and other resources in the alleged ancestral land.
- Petitioners alleged that respondents violated the conditions of the Environmental Compliance Certificate (ECC) and that the respondents’ project posed grave and irreparable danger to the environment, life, and property in violation of PD No. 1586.
- Respondent Baguio Properties, Inc. contended that petitioners’ action constituted a collateral attack on Torrens titles and invoked ownership over the subject land.
- Petitioners attached an NCIP report and recommendation stating that petitioners were established as heirs of Tunged and that the subject land formed part of the tract possessed by Tunged and successors.
Statutory Framework
- Republic Act No. 8371 (IPRA) provides recognition of ancestral domain rights and establishes the National Commission on Indigenous Peoples (NCIP) with limited jurisdiction under Section 66 and recognition procedures under Section 11.
- PD No. 1586 established the Environmental Impact Statement System and governs issuance and compliance with ECCs.
- Administrative Matter No. 09-6-8-SC (A.M. No. 09-6-8-SC) prescribes the Rules of Procedure for Environmental Cases, including verified complaint requirements and who may file under Section 4 and referral of non-environmental complaints under Section 3, Rule 2.
- Administrative Order No. 23-2008, in relation to Batas Pambansa Blg. 129 (BP 129), designated the RTC as a special court to hear environmental cases within its territorial jurisdiction.
Issues Presented
- Whether the court a quo’s outright dismissal of Environmental Case No. 8548-R for lack of jurisdiction was proper.
Contentions of the Parties
- Petitioners contended