G.R. No. 209691 . January 16, 2023.
GABRIEL B. DICLAS, ET AL., PETITIONERS, VS. MAXIMO BUGNAY, SR., RESPONDENT.

FACTS

Petitioners, members of the Ibaloi and Kankana-ey tribes, claimed ownership of ancestral lands in Baguio City, tracing their lineage to a pioneer Ibaloi named Bilag. They asserted that Bilag either bequeathed the land to his Ibaloi descendants or donated portions to Kankana-ey helpers, who have since occupied, cultivated, and built homes and tombs on the land. Prior to the Indigenous Peoples’ Rights Act (IPRA), they filed townsite sales applications with the DENR, some receiving orders of award. In 2007, they discovered that the National Commission on Indigenous Peoples (NCIP) had issued Certificates of Ancestral Land Title (CALTs) over the same parcels to respondent Maximo Bugnay, Sr., an Ibaloi who traced his claim to his great-grandfather. Petitioners filed a Petition for Cancellation before the NCIP, alleging Bugnay, Sr. obtained the titles through fraud, violated delineation procedures, and later executed documents constituting an illegal transfer to non-indigenous parties.
The NCIP denied the petition, finding Bugnay, Sr.’s evidence of ancestral claim stronger. The Court of Appeals affirmed the NCIP. Petitioners elevated the case to the Supreme Court, arguing the NCIP and CA erred in disregarding their evidence of possession and the alleged violations in the titling process.

ISSUE

Whether the Court of Appeals erred in upholding the NCIP’s factual findings and its denial of the Petition for Cancellation of the CALTs issued to Maximo Bugnay, Sr.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ rulings. The Court emphasized that factual findings of administrative agencies like the NCIP, when affirmed by the Court of Appeals, are accorded great weight and respect and are binding on the Supreme Court, absent any clear showing of arbitrariness or manifest misapprehension of facts. The core of the dispute was a factual question: who presented superior proof of ownership under the IPRA’s framework for ancestral lands? The NCIP, as the specialized agency, evaluated the conflicting evidence, including competing narratives of lineage, possession, and historical claims. It found Bugnay, Sr.’s evidence, which included a 1963 survey and a consistent application for recognition since 1990, more credible and sufficient to establish his ancestral claim. Petitioners’ evidence, including townsite sales applications, was deemed not to preempt or negate a valid ancestral claim recognized under the IPRA regime. The Court found no arbitrariness in this assessment. On the legal issue of alleged invalid transfer via a special power of attorney and joint venture agreement, the Court ruled this was a collateral attack on the title, which is prohibited. A certificate of title cannot be challenged collaterally but only in a direct proceeding for its cancellation or nullity. The proper remedy for petitioners, if they believed the titles were void from the beginning, was a direct action for nullity, not a petition for cancellation based on alleged post-titling acts. Therefore, the NCIP and CA committed no reversible error.