GR 223434; (July, 2019) (Digest)
G.R. No. 223434 July 3, 2019
SUSAN GALANG, et al., Petitioners, vs. VERONICA WALLIS, et al., Respondents.
FACTS
Petitioners, representing various successors-in-interest, filed a Complaint for Accion Reivindicatoria, Declaration of Nullity of a survey plan and tax declaration, Injunction, and Damages with the Regional Trial Court (RTC) of La Trinidad, Benguet. They claimed ownership over parcels of land in Ampucao, Itogon, Benguet, tracing their title to a 1973 Deed of Absolute Sale from a prior occupant. They alleged that respondents intruded upon the land using fraudulently acquired documents.
Respondents moved to dismiss, asserting the RTC lacked jurisdiction. They contended the land was ancestral land and all parties were members of indigenous peoples’ groups, placing the dispute under the exclusive jurisdiction of the National Commission on Indigenous Peoples (NCIP). They supported this with a 1998 Resolution from a Community Task Force granting an ancestral land claim to the Heirs of Toato Bugnay, whom they represented.
ISSUE
Whether the Regional Trial Court correctly dismissed the case for lack of jurisdiction, holding that the National Commission on Indigenous Peoples has exclusive jurisdiction over the dispute concerning the subject land.
RULING
Yes, the RTC correctly dismissed the case. The Supreme Court affirmed that jurisdiction over the dispute lies with the NCIP, not the regular courts. The legal logic rests on the application of Republic Act No. 8371, the Indigenous Peoples’ Rights Act (IPRA). Section 66 of the IPRA explicitly grants the NCIP jurisdiction over all claims and disputes involving rights of Indigenous Cultural Communities/Indigenous Peoples. The Court found the subject matter of the complaint—a claim of ownership and possession over land asserted to be ancestral domain—falls squarely within this provision.
Crucially, the Court noted that the allegations in the complaint and the evidence presented, particularly the 1998 Resolution recognizing an ancestral land claim in favor of respondents’ predecessors, sufficiently established that the property is a claimed ancestral land and that the parties are members of indigenous groups. This characterization of the dispute triggers the NCIP’s primary jurisdiction. The Court emphasized that the NCIP’s jurisdiction is not diminished by the nature of the action (e.g., accion reivindicatoria) or the documents involved (e.g., a tax declaration). When the core controversy involves rights to ancestral domains/lands, the IPRA mandates that the NCIP exercise its specialized expertise first. Therefore, the RTC properly applied the doctrine of primary jurisdiction and correctly relinquished the case to the NCIP for appropriate proceedings.