G.R. No. 209449, July 30, 2024
Republic of the Philippines, Petitioner, vs. National Commission on Indigenous Peoples, Register of Deeds – Baguio City, Land Registration Authority, Heirs of Lauro Carantes, Dimson Manila, Inc., Joan L. Gorio, and Certain Jane Does and John Does, Respondents.

FACTS

This case involves a Petition for Recognition and Delineation of Ancestral Land Claim filed by the heirs of Lauro Carantes over properties within Baguio City. The National Commission on Indigenous Peoples (NCIP) processed the claim. The Republic of the Philippines, through the Office of the Solicitor General, filed a petition challenging the claim. The Court of Appeals upheld the NCIP’s processes. In a Decision dated July 11, 2023, the Supreme Court granted the Republic’s Petition for Review on Certiorari, setting aside the Court of Appeals’ rulings and holding that Certificates of Ancestral Land Titles (CALTs) could not be issued to the heirs. The Court ruled that Baguio City is exempt from the coverage of the Indigenous Peoples’ Rights Act (IPRA) by virtue of its own charter under Section 78 of IPRA, except for claims of native title based on ownership since time immemorial. The Court also found that the heirs failed to prove the required occupation and possession since time immemorial, as the claimed land was occupied by other entities (Camp John Hay, Baguio Country Club, Baguio Water District) and was part of a forest park reservation. The respondents (NCIP, Heirs of Lauro Carantes, and Joan L. Gorio) filed Motions for Reconsideration, arguing that the Republic was not denied due process, that Section 78 does not exclude Baguio City from IPRA coverage, and that the heirs sufficiently established their ancestral claim.

ISSUE

Whether the Motions for Reconsideration should be granted, thereby reversing the Court’s July 11, 2023 Decision which denied the issuance of CALTs to the heirs of Lauro Carantes over lands in Baguio City.

RULING

The Supreme Court DENIED the Motions for Reconsideration with finality and AFFIRMED its July 11, 2023 Decision. The Court held that the issues raised had already been duly considered. It reiterated and clarified its ruling: Baguio City is exempt from the coverage of IPRA, except for claims of native title. Native title refers to ownership since time immemorial, independent of any Spanish grant, where indigenous peoples are in open, continuous, exclusive, and actual possession of the land up to the present. This concept, established in Cariño v. Insular Government, is an exception to the Regalian Doctrine. However, claims to native title must be proven through the regular land titling process, not through IPRA. The Court found that the heirs of Carantes failed to prove the essential element of actual, continuous possession since time immemorial up to the present. The land claimed was occupied by other parties with vested rights and was designated as a forest park reservation. Therefore, no presumption of private ownership arose, and the CALTs could not be issued.