G.R. No. 192112 , August 19, 2020
ELIZABETH B. RAMOS, ET AL., PETITIONERS, VS. NATIONAL COMMISSION ON INDIGENOUS PEOPLES (NCIP), QUEEN ROSE T. CABIGAS, ET AL., RESPONDENTS.

FACTS

The dispute involves land in Malalag, Davao del Sur. Petitioners are heirs of 133 awardees granted 399 hectares by a 1957 Office of the President Amended Decision, which became final. The remaining 317 hectares were awarded to the heirs of Orval Hughes. In 2003, Bae Lolita Buma-at Tenorio of the Egalan-Gubayan clan applied for a Certificate of Ancestral Land Title (CALT) over the same area. The NCIP issued CALT No. Rll-MAL-0905-000049 in 2005. Meanwhile, agrarian cases involving the Hughes heirs’ portion culminated in a 2005 Supreme Court decision affirming DARAB jurisdiction and ordering the Hughes heirs to vacate and restore possession to petitioners and other farmers.
A Writ of Execution was issued in 2008 to enforce this DARAB decision. In response, minor members of the Egalan-Gubayan clan filed an injunction case before the NCIP Regional Hearing Officer (RHO) to stop the execution, claiming the land was their ancestral domain. The RHO dismissed the complaint for forum-shopping and lack of jurisdiction. The NCIP Commission Proper reversed the RHO, asserting its primary jurisdiction over ancestral domain claims and issuing a TRO against the writ’s enforcement.

ISSUE

Whether the NCIP committed grave abuse of discretion in taking cognizance of the injunction case and enjoining the execution of a final DARAB decision.

RULING

Yes, the NCIP committed grave abuse of discretion. The Supreme Court ruled that the NCIP’s jurisdiction is not primary and exclusive when a prior, final judgment from a court or quasi-judicial body of competent jurisdiction has already settled the rights of the parties over the same property. The 1957 OP Decision, which became final and executory, already adjudicated the land in favor of the 133 awardees (petitioners’ predecessors) and the Hughes heirs. This decision was affirmed by the Supreme Court in subsequent rulings. The issuance of the CALT in 2005, long after the OP decision became final, could not validly amend or supersede that final judgment.
The legal logic is anchored on the doctrine of finality of judgment and the hierarchy of courts. A final judgment is immutable and unalterable. The NCIP, in entertaining the injunction suit, effectively allowed a collateral attack on these final judgments. Its assertion of jurisdiction under the Indigenous Peoples’ Rights Act (IPRA) was misplaced because the IPRA itself, under Section 56, respects existing property rights recognized under other laws. The rights of petitioners, vested by a final OP decision, constitute such existing rights. Therefore, the NCIP’s act of reversing its RHO and assuming jurisdiction constituted a capricious and whimsical exercise of power, amounting to grave abuse of discretion correctible by certiorari. The Court reinstated the RHO’s dismissal order.