Case Summary (G.R. No. 252834)
Applicable Law
The governing framework includes the 1987 Constitution of the Philippines and Presidential Decree No. 705, henceforth known as the "Revised Forestry Code." These laws establish the state's ownership of lands of the public domain, asserting a framework where only lands classified as agricultural may be alienable.
Background of the Case
Timario et al. filed a citizen suit on October 30, 2015, claiming rights and obligations under environmental laws, seeking to cancel tax declarations held by the petitioners, and requesting environmental protection orders to safeguard public lands used by the community for agricultural and cultural practices. The land in question has been purportedly used for farming activities, which Timario et al. alleged results in environmental degradation, violating the rights to a balanced ecology.
Allegations Against Petitioners
Timario et al. accused the petitioners of engaging in destructive activities, such as bulldozing, land conversion for agriculture, and using harmful agricultural chemicals that could pollute the surrounding environment. They argued that these actions not only violated environmental laws but also restricted public access to communal lands traditionally used by the residents of Barangay Data.
Response from Petitioners
Spouses Maliones countered the claims, asserting ownership based on ancestral rights and the legality of their activities. They maintained that their land was previously declared for tax purposes and contended that the environmental assertions from Timario et al. were exaggerated or unfounded. They highlighted that their activities only included refurbishing their property, not extensive earth-moving or destruction.
Court Proceedings
The Regional Trial Court (RTC) issued a Temporary Environmental Protection Order (TEPO) on November 5, 2015, requiring the petitioners to cease specific activities on the land. Following this, the RTC ruled favorably for Timario et al., mandating the cessation of activities damaging to the environment and asserting the land's classification as part of the public forest beyond alienable property.
Appeals and Appellate Court Decisions
The petitioners appealed the RTC decision to the Court of Appeals (CA), which affirmed the RTC's ruling and dismissed the petitioners' appeal as lacking merit. The CA held that the claims for ownership presented by the petitioners did not remove the presumption of state ownership of the land in question.
Supreme Court Ruling
Upon reaching the Supreme Court, the core issue revolved around whether Spouses Maliones could validly claim ownership under native title enough to evade compliance with the environmental protection order and the writ of continuing mandamus. The Court asserted that even if petitioners' claims of ancestral land were considered, the lack
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Background and Parties Involved
- Petitioners: Spouses Robles and Rose Maliones (a.k.a Rosa Maliones), Spouses Eduardo and Rosita Quiao, Mr. Eugenio Sawate, and the late George Bati-el represented by his wife Lilia Bati-el, among others.
- Respondents: Mario S. Timario, Jr., and multiple co-respondents including local community members from Barangay Data, Sabangan, Mountain Province.
- Originated from cases concerning land situated in Am-amoting, Batacang/Ambango, Barangay Data, Sabangan, Mountain Province.
- The subject land is classified as "outside the Alienable and Disposable Zone" under a 1956 certification by the Director of Forestry.
- The disputes involve allegations of illegal occupation, destruction, and conversion of public forest lands.
Nature of the Case and Claims
- The respondents filed a citizen suit alleging violation of environmental laws, including Presidential Decree No. 705 (Revised Forestry Code).
- Allegations include illegal earth-moving, bulldozing, conversion of forest land into vegetable farms, use of harmful fertilizers and pesticides, cutting and girdling of trees, and kaingin (slash-and-burn) activities.
- Petitioners (Spouses Maliones et al.) were accused of illegally fencing off portions of the land, restricting public access, and committing environmental damage.
- Respondents pray for:
- Cancellation of disputed tax declarations.
- Environmental protection orders (temporary and permanent).
- Mandamus directing government agencies and local officials to enforce environmental laws and halt illegal activities.
Claims by Petitioners (Spouses Maliones et al.)
- Denied accusations and argued that activities were limited to soil refurbishment, not destructive earth-moving.
- Maintained the land was ancestral property, purportedly declared for tax purposes in 1970 by the late John Miguel and subsequently sold to them in 2012.
- Asserted preservation of natural beauty and absence of environmental harm.
- Contended no trees were cut or girdled and fencing was to protect crops from animals.
Procedural History
- The Regional Trial Court (RTC) issued a Temporary Environmental Protection Order (TEPO) stopping alleged damaging activities.
- The RTC decision (Oct 10, 2016) was largely in favor of the respondents, permanently enjoining private respondents from destructive acts and ordering government agencies to enforce laws, refrain from issuing unauthorized tax declarations, and to investigate propriety of said declarations.
- The Court of Appeals (CA) affirmed the RTC decision, ruling that the respondents have legal standing under the citizen suit doctrine to protect public forest lands.
- CA denied the motion for reconsideration filed by the petitioners.
- The petitions were consolidated by the Supreme Court for final resolution.
Legal Issues Presented
I. Whether the petitioners Spouses Maliones et al. can use their claim of ancestral/native ownership to prevent the Court from granting reliefs sought in the environmental citizen suit. II. Whether the reliefs awarded by the lower courts were proper and within legal bounds.