GR 208480; (September, 2019) (Digest)
G.R. No. 208480 , September 25, 2019
Republic of the Philippines, Petitioner, vs. National Commission on Indigenous Peoples, Register of Deeds of Baguio City, Land Registration Authority, 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, and Virginia C. Gao-an, Respondents.
FACTS
The National Commission on Indigenous Peoples (NCIP) issued Certificates of Ancestral Land Title (CALTs) in favor of the Heirs of Cosen Piraso and the Heirs of Josephine Molintas Abanag through Resolutions Nos. 107-2010-AL and 108-2010-AL, both dated November 10, 2010. The NCIP found that the Pirasos and Abanags, as Ibaloi natives, had vested rights over the subject lands in Baguio City based on native title, as mandated by the 1987 Constitution and the Indigenous Peoples’ Rights Act (IPRA or R.A. No. 8371 ). The NCIP directed the issuance of eight CALTs for the Pirasos and twenty-eight CALTs for the Abanags. Subsequently, the Land Registration Authority issued corresponding Transfer Certificates of Title. The Republic of the Philippines, through the Office of the Solicitor General, filed a petition to annul the NCIP Resolutions. The Court of Appeals dismissed the Republic’s petition, agreeing with the NCIP that Baguio City is not excluded from IPRA’s coverage. The Republic elevated the case to the Supreme Court via a Petition for Review.
ISSUE
Whether the NCIP has jurisdiction to issue Certificates of Ancestral Land Title over lands within Baguio City.
RULING
The Supreme Court GRANTED the petition. The NCIP has no jurisdiction to issue CALTs over lands in Baguio City. The Court declared NCIP Resolution Nos. 107-2010-AL and 108-2010-AL, and all CALTs and derivative titles issued pursuant thereto, NULL and VOID.
The Court ruled that Baguio City is excluded from the coverage of the IPRA. The legislative history of the IPRA reveals a clear intent to exclude the City of Baguio from its application. During the bicameral conference committee deliberations, the provision stating “The City of Baguio shall remain to be governed by its Charter and all lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation” was specifically adopted. This exclusion is rooted in the unique land tenure system of Baguio City, established under its Charter ( Act No. 926 ) and related laws, which governs the disposition of its townsite reservation. The IPRA itself, in its Section 78, provides that “The City of Baguio shall remain to be governed by its Charter and all lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation.” Therefore, the NCIP acted without jurisdiction in issuing the assailed CALTs over lands within Baguio City.