G.R. No. 81561 - People vs. Marti

Case Summary (G.R. No. 81561)

Key Dates and Governing Law

Applicable constitutional framework: 1987 Philippine Constitution (Article XII, Section 5 referenced by NCIP). Primary statutory law: Republic Act No. 8371 (Indigenous Peoples’ Rights Act of 1997, “IPRA”), including Section 78 and Section 8; implementing rules (IPRA IRR, Rule XIII, Section 1). Other statutory background relied on: Act No. 926 (Public Land Act), Act No. 627 (procedure for reservations), Land Registration Act (Act No. 496). Relevant prior jurisprudence: Civil Reservation/Expediente de Reserva No. 1 (Baguio Townsite Reservation, CFI decision 1922) and Republic v. FaAgonil.

Factual Background

Heirs of Cosen Piraso and heirs of Josephine Molintas Abanag filed petitions with NCIP for identification, delineation and recognition of ancestral lands in Baguio City pursuant to RA 8371. NCIP conducted fact-finding (including genealogy, ocular inspection, documentary evidence, rituals, photographs, tax receipts, and narratives). NCIP issued Resolution No. 107‑2010‑AL granting eight CALTs to the Pirasos and related persons, and Resolution No. 108‑2010‑AL granting twenty‑eight CALTs to the Abanags and related transferees. The LRA subsequently issued corresponding TCTs based on those CALTs.

NCIP’s Legal Characterization and Rulings

NCIP characterized the private respondents’ rights as native title—rights and interests in land derived from traditional laws and customs of indigenous inhabitants—and invoked the protection mandated by Article XII, Section 5 of the 1987 Constitution and Section 8 of RA 8371. The NCIP directed preparation of CALTs for specific parcel numbers and identified named beneficiaries for each parcel in the dispositive portions of both Resolutions.

Court of Appeals Ruling

The Court of Appeals denied the Republic’s petition for certiorari, prohibition and mandamus, agreeing with NCIP that IPRA applies to Baguio City and that the NCIP Resolutions were valid. The CA thus affirmed the issuance of the CALTs and denied injunctive relief as moot or academic.

Issues on Review

The Republic raised, among others: (1) whether lands within Baguio City and the Baguio Townsite Reservation are covered by IPRA; (2) whether NCIP had jurisdiction to issue CALTs over the subject townsite reservation lands absent prior recognized titles or congressional reclassification; and (3) whether CALTs can be converted into Torrens certificates of title (TCTs).

Supreme Court’s Legal Standard and Statutory Interpretation

The Court applied the 1987 Constitution as the governing constitutional basis. It construed RA 8371, giving particular weight to Section 78 as a special provision for Baguio City that operates to exclude the City’s townsite reservation lands from the general titling/reclassification powers under IPRA. Section 78 provides that Baguio shall remain governed by its charter, that lands proclaimed as part of its townsite reservation shall remain such unless reclassified by appropriate legislation, and that prior land rights and titles recognized/acquired before IPRA remain valid. The Court also relied on the IPRA Implementing Rules (Rule XIII, Section 1) reiterating that reclassification of Baguio Townsite Reservation lands requires legislation.

Legislative Intent and Congressional Deliberations

The Court examined the legislative history reflected in the House and Senate deliberations on IPRA, finding a clear and deliberate congressional intent to exempt Baguio City’s townsite reservation from the general titling provisions of IPRA and to preserve the governance of lands under Baguio’s charter unless Congress reclassifies them.

Historical and Doctrinal Background on Baguio Townsite Reservation

The Court recited the 1912 establishment of the Baguio Townsite Reservation and the subsequent Civil Reservation Case No. 1 (GLRO Reservation Record No. 211), culminating in the CFI decision of 13 November 1922 that effectively declared the reservation lands public domain except for specific public uses and adjudicated private lands, and that claims not registered within the period fixed in Act No. 627 were barred forever. The Court invoked Section 62 of Act No. 926, the procedure under Act No. 627 for townsite reservations, and the doctrine that registration opportunities afforded by the reservation proceedings were conclusive. The Court relied on Republic v. FaAgonil to underscore that claims within the townsite reservation that were not presented and adjudicated in the 1912–1922 proceedings could not thereafter be registered or treated as private rights.

Application of Law to the Present Case

Applying Section 78 of RA 8371 and the reservation precedent, the Court concluded that NCIP lacked authority to issue CALTs or CADTs over parcels located within the Baguio Townsite Reservation that were part of the reservation prior to the effectivity of IPRA, except insofar as prior land rights or titles had been recognized before IPRA or for territories incorporated into Baguio after IPRA. Because the private respondents’ claimed rights over the subject parcels were not previously recognized in any judicial or administrative proceedings before the effectivity of IPRA, their claims did not fall within the Section 78 exceptions. The Court thus determined that the NCIP Resolutions transcended the l

Case Syllabus (G.R. No. 81561)

Case Citation, Nature of the Case, and Procedural Posture

Reported at 863 Phil. 908; 116 OG No. 48, 7848 (November 30, 2020); Second Division, G.R. No. 208480, September 25, 2019.
Petition for Review under Rule 45 of the Rules of Court filed by the Republic of the Philippines through the Office of the Solicitor General (OSG).
The petition assails the Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 126498 dated 15 January 2013 and 22 July 2013, which dismissed the Republic’s petition for certiorari, prohibition and mandamus with prayer for TRO and/or writ of preliminary injunction against the NCIP.
Lower rulings affirmed the NCIP Resolutions (Nos. 107-2010-AL and 108-2010-AL, both dated 10 November 2010) that ordered issuance of Certificates of Ancestral Land Title (CALTs); subsequent Transfer Certificates of Title (TCTs) were issued by the Land Registration Authority (LRA).

Parties

Petitioner: Republic of the Philippines (represented by the Office of the Solicitor General).
Public Respondents: National Commission on Indigenous Peoples (NCIP); Register of Deeds of Baguio City; Land Registration Authority (LRA).
Private Respondents: Heirs of Cosen Piraso (represented by Richard A. Acop); Heirs of Josephine Molintas Abanag (represented by Isaias M. Abanag); Marion T. Pool; Joan L. Gorio; Virginia C. Gao-an.

Reliefs Sought by Petitioner

Annulment, reversal, and setting aside of NCIP Resolutions Nos. 107-2010-AL and 108-2010-AL.
Declaratory relief that NCIP has no jurisdiction to issue CALTs/CADTs over lands in Baguio City and the Baguio Townsite Reservation, except for prior recognized land rights/titles.
Injunctive relief: writ of preliminary prohibitory injunction and permanent injunction restraining NCIP from issuing CADTs and CALTs in Baguio City.
Declaration that any conversion of CALTs into Torrens titles (TCTs) is unauthorized and void.

Antecedent Facts (as found by the Court of Appeals and narrated in the record)

NCIP Resolutions issued CALTs in favor of:
- Heirs of Cosen ("Sarah") Piraso and Manuel Nimer (adopted son of Piraso) (Resolution No. 107-2010-AL) — eight (8) CALTs ordered.
- Heirs of Josephine Molintas Abanag and transferees including Joan L. Gorio, Virginia C. Gao-an, Marion T. Pool, Isaias Abanag (Resolution No. 108-2010-AL) — twenty-eight (28) CALTs ordered.
Facts regarding Piraso claim:
- Kapitan Piraso (Ibaloi) occupied ancestral land at what is known as Session Road, Baguio City.
- He had five children and an adopted son, Nimer, according to Ibaloi tradition; Nimer and family cultivated vegetables and fruit-bearing trees on portions of the ancestral land.
- Petition for identification, delineation and recognition filed with Baguio NCIP City Office under RA 8371 (IPRA); NCIP found an unbroken genealogy for 120 years and ordered eight CALTs (including one in the name of Manuel Nimer).
Facts regarding Molintas/Abanag claim:
- Josephine Molintas Abanag descended from Menchi, an Ibaloi native who originally owned several parcels in what is now Baguio City.
- Petitioners submitted ocular inspection results and numerous documentary pieces of evidence (narratives of customs and traditions, assessment of real property, tax receipts, photographs of improvements, rituals, and family photographs).
- NCIP ordered issuance of twenty-eight CALTs in the names of the petitioners and transferees including Joan L. Gorio and Virginia C. Gao-an.
Petitioners (private respondents) provided a Deed of Undertaking supporting their claim.

NCIP Resolutions: Legal Basis, Definition of Native Title, and Dispositive Orders

NCIP grounded its actions on Article XII, Section 5 of the 1987 Constitution and RA 8371 (Indigenous Peoples’ Rights Act of 1997).
NCIP’s description of native title (as cited in the resolutions):
- Native title defined as "the interests and rights of indigenous inhabitants in land, whether communal, group or individual, possessed under the traditional laws acknowledged by, and the traditional customs observed by, the indigenous inhabitants."
- Native title "has its origin in and is given its content by the traditional laws acknowledged by and the traditional customs observed by the indigenous inhabitants of a territory. The nature and incidents of native title must be ascertained as a matter of fact by reference to those laws and customs."
Dispositive portion of Resolution No. 107-2010-AL (10 November 2010):
- GRANTED petition and directed Ancestral Domains Office to prepare eight (8) CALTs bearing CAR-BAG-1110-000268 to CAR-BAG-1110-000275.
- Allocation: Lot 1 — Manuel Nimer; Lots 2, 3, 4 — Heirs of Cosen Piraso represented by Richard A. Acop; Lots 3, 5, 6, 7, 8 — Joan L. Gorio (as reflected in the resolution text).
- Petitioners guaranteed right to ancestral lands under Section 8, RA 8371.
Dispositive portion of Resolution No. 108-2010-AL (10 November 2010):
- GRANTED petition and directed preparation of 28 CALTs bearing CAR-BAG-1110-000276 to CAR-BAG-1110-000303.
- Detailed allocation by lot to Heirs of Josephine Abanag/Heirs of Mercedes A. Tabon (represented by Isaias Abanag and Marion T. Pool), Joan L. Gorio, Virginia C. Gao-an, and split allocations for parts of Lots 17 and 28 (specified square meter allocations to Isaias Abanag).
- Petitioners guaranteed rights under Section 8, RA 8371.

Issuance of Derivative Titles

The Land Registration Authority (LRA) issued corresponding Transfer Certificates of Title (TCTs) covering the properties for which CALTs were issued (O-CALT Nos. 129 and 130 and corresponding TCT numbers referenced in the record).

Court of Appeals Ruling (15 January 2013)

The Court of Appeals affirmed the NCIP Resolutions.
CA’s key finding: "agrees with the finding of the NCIP that Baguio City is no different from any part of the Philippines and that there is no sensible difference that merits the city's exclusion from the coverage of the IPRA."
Dispositive portion: denied the petition for lack of merit; denied prayer for TRO/preliminary injunction as moot and academic; affirmed NCIP Resolution Nos. 107-2010-AL and 108-2010-AL.

Issues Framed by the Republic in the Petition

Whether the Court of Appeals committed reversible error in declaring that lands within Baguio City and the Baguio Townsite Reservation are covered by IPRA.
Whether the Baguio Townsite Reservation (except existing property rights recognized or vested before IPRA) is exempt from IPRA coverage under Section 78.
Whether NCIP has jurisdiction to issue CALTs over lands within Baguio City and the Baguio Townsite Reservation outside pre-existing recognized prior land rights and titles.
Whether the CA erred in ruling that the assailed NCIP resolutions are valid, in light of the Constitution, applicable laws, and jurisprudence.
Whether CALTs, if assumed valid, could be converted into Torrens certificates of title (TCTs) — with the Republic’s contention that no law allows such conversion.

Arguments Advanced by the Republic (as presented in the petition)

NCIP lacks jurisdiction to issue CALTs/CADTs covering lands within Baguio City Townsite Reservation except for prior land rights and titles recognized/acquired before IPRA’s effectivity.
Section 78 of RA 8371 expressly excludes the City of Baguio and townsite reservation lands from general application of IPRA and provid