GR 181284; (April, 2017) (Digest)
G.R. No. 181284 EN BANC April 18, 2017
LO LOY UNDURAN, ET AL., Petitioners vs. RAMON ABERASTURI, ET AL., Respondents
FACTS
Respondents, the heirs of the late Don Mariano Lopez, Sr., filed a complaint for recovery of possession, ownership, and damages against petitioners before the Regional Trial Court (RTC) of Gingoog City. The complaint alleged that petitioners, some of whom are members of the Higaonon tribe, unlawfully entered and occupied portions of the Lopez family’s titled properties. Petitioners moved to dismiss the case, asserting that the land in dispute is part of their ancestral domain. They argued that jurisdiction lies with the National Commission on Indigenous Peoples (NCIP) under the Indigenous Peoples’ Rights Act (IPRA), not with the regular courts.
ISSUE
Whether the RTC or the NCIP has jurisdiction over the complaint for recovery of possession filed by private landowners against individuals claiming ancestral domain rights.
RULING
The Supreme Court DENIED the Motion for Reconsideration and AFFIRMED its prior Decision, ruling that the RTC retains jurisdiction. The Court held that the determination of jurisdiction is governed by the allegations in the complaint. The respondents’ complaint is a straightforward action for recovery of possession based on alleged torrens titles, falling squarely within the general jurisdiction of the RTC. Petitioners’ invocation of ancestral domain rights, while raised in their motion to dismiss, constitutes a mere defense that does not divest the RTC of its jurisdiction over the subject matter as framed by the complaint.
The Court rejected the analogy to tenancy or labor cases, clarifying that the exceptions allowing a defendant’s allegations to affect jurisdiction in those specialized areas do not apply to claims under the IPRA in disputes with non-IPs. The Court reiterated its interpretation of Section 66 of the IPRA, which grants the NCIP jurisdiction over claims and disputes involving rights of ICCs/IPs only when they arise between or among parties belonging to the same ICC/IP. Since this case involves a dispute between IP claimants and non-IP private landowners, it falls outside the primary jurisdiction of the NCIP. The Court emphasized that the IPRA did not divest regular courts of jurisdiction over all land disputes; it created a limited jurisdiction for the NCIP over specific intra-IP matters. The petitioners’ remedy is to prove their claim of ancestral domain as a defense in the RTC, which is competent to hear and evaluate such evidence.