In a pivotal decision, the Supreme Court clarified the jurisdiction of Regional Trial Courts (RTCs) in reversion cases involving lands covered by Certificates of Ancestral Land Titles (CALTs). The Court held that RTCs possess the authority to hear cases seeking the reversion of land to the public domain and the cancellation of titles, even if those titles originated from resolutions issued by the National Commission on Indigenous Peoples (NCIP). This ruling ensures that the State has recourse to protect public lands from potentially invalid ancestral land claims. This decision emphasizes the crucial role of RTCs in safeguarding public land and resolving disputes involving indigenous land rights and government interests, ensuring a balance between protecting ancestral domains and upholding the integrity of land titles.

When Public Land Claims Clash with Indigenous Rights: Who Decides?

The Republic of the Philippines, represented by officials from the Bureau of Animal Industry and the Department of Agriculture, filed a complaint against the Heirs of Ikang Paus, seeking the reversion of certain lands and the cancellation of titles. The contested land was covered by Original Certificate of Title (OCT) No. 0-CALT-37, issued based on a Certificate of Ancestral Land Title (CALT) granted to the Heirs of Ikang Paus by the NCIP. The Republic argued that the land in question was part of the Baguio Stock Farm (BSF), a government reservation established under Presidential Proclamation No. 603, series of 1940. According to the Republic, the issuance of the CALT and subsequent OCT was irregular and violated the provisions of the Indigenous Peoples Rights Act (IPRA) and other relevant laws. This legal battle raised a fundamental question: Which court has the authority to adjudicate disputes involving ancestral land titles that overlap with public land claims?

The RTC of Baguio City dismissed the Republic’s complaint, citing a lack of jurisdiction over the subject matter. The RTC reasoned that since the complaint challenged the validity of the CALT and the underlying NCIP resolution, it would essentially be reviewing a decision of a co-equal body, which is beyond its power. The Court of Appeals (CA) affirmed the RTC’s decision, agreeing that the NCIP and RTC are co-equal bodies, and the NCIP is beyond the control of the RTC. The Republic then elevated the case to the Supreme Court, arguing that the RTC has the power to examine the NCIP’s decision, especially when it is patently null and void, and to annul an OCT issued based on such a decision. Now the Supreme Court was called upon to resolve the jurisdictional question and clarify the respective roles of the RTC and the NCIP in resolving land disputes involving ancestral land claims and public land reservations.

The Supreme Court began its analysis by reiterating the principle that jurisdiction is determined by the allegations in the complaint, the applicable law, and the nature of the relief sought. The Court emphasized that the Republic’s complaint was not merely a review of the NCIP’s resolution but a reversion case seeking to return land to the public domain and cancel a Torrens title. According to the Court, this is a crucial distinction. The high court emphasized that the Republic’s complaint attacked OCT No. 0-CALT-37 because it arose from Resolution No. 060-2009-AL, which the Republic claims was not validly rendered. The Court underscored that in ruling on the validity of OCT No. 0-CALT-37, the Court will necessarily rule on the validity of CALT No. CAR-BAG-0309-000207 and the reconstructed and unapproved survey plan together with the technical description of Lot 1, SWO-14110215703-D-A-NCIP, all of which were issued and approved in Resolution 060-2009- AL.

The Court cited Batas Pambansa Blg. 129, which grants RTCs exclusive original jurisdiction over civil actions involving title to or possession of real property. The Court further cited the case of Republic v. Roman Catholic Archbishop of Manila, which held that actions for cancellation of title and reversion fall under the jurisdiction of the RTC when the assessed value of the property exceeds a certain threshold. Building on this legal framework, the Court concluded that the RTC had jurisdiction over the Republic’s complaint because it involved a reversion suit seeking to cancel a Torrens title covering public land. The Court pointed out that in resolving this issue, the RTC may need to examine the validity of the NCIP’s proceedings that led to the issuance of the title, but this does not negate the RTC’s jurisdiction over the reversion case. As the Court held in Malabanan v. Republic:

“[I]n a reversion suit, we should emphasize, the attack is directed not against the judgment ordering the issuance of title, but against the title that is being sought to be cancelled either because the judgment was not validly rendered, or the title issued did not faithfully reflect the land referred to in the judgment, or because no judgment was rendered at all.”

Moreover, the Court emphasized that the NCIP’s jurisdiction is limited to disputes involving rights of Indigenous Cultural Communities (ICCs)/Indigenous Peoples (IPs), as provided in Section 66 of the IPRA. As the Court held in Lim v. Gamosa, the NCIP has no power to decide controversies involving non-ICCs/IPs, even if the dispute involves rights of ICCs/IPs. Since the Republic, the Register of Deeds of Baguio, and the LRA are non-ICCs/IPs, the NCIP cannot rule on their rights, and the dispute should be brought before a court of general jurisdiction, which in this case is the RTC.

The Court also addressed the Petition-in-Intervention filed by the Heirs of Mateo Cariño and Bayosa Ortega, who sought to challenge the constitutionality of Section 53 of the IPRA. The Court denied the intervention, finding that the Heirs of Cariño and Ortega failed to prove a legal interest in the controversy and that ruling on the constitutionality of Section 53 would delay the adjudication of the main issue. The Court stressed that the constitutionality of a law should only be decided when it is the very lis mota of the case, which was not the situation here. This approach reinforces the principle of judicial restraint, where courts avoid ruling on constitutional questions unless absolutely necessary to resolve the dispute before them. Furthermore, the Court reiterated that the constitutionality of a law should only be decided when it is the very lis mota of the case.

Ultimately, the Supreme Court held that the RTC committed grave abuse of discretion in dismissing the Republic’s complaint for lack of jurisdiction. The Court reversed the CA’s decision and remanded the case to the RTC for trial on the merits. The Court also denied the Petition-in-Intervention. The Court’s decision clarifies the jurisdictional boundaries between the RTC and the NCIP in land disputes involving ancestral land claims and public land reservations, providing guidance for future cases of this nature.

This ruling serves to protect the rights and interests of the Republic over public lands, while also acknowledging the importance of respecting the rights of indigenous peoples. It reinforces the principle that all land disputes, regardless of their complexity, must be resolved within the framework of the law, with due regard for the rights of all parties involved.

FAQs

What was the key issue in this case?	The central issue was whether the Regional Trial Court (RTC) has jurisdiction over a case filed by the Republic of the Philippines seeking the reversion of land to public domain and cancellation of title, when the title originated from a Certificate of Ancestral Land Title (CALT) issued by the National Commission on Indigenous Peoples (NCIP).
What is a reversion case?	A reversion case is a legal action filed by the government to reclaim ownership of land that was allegedly illegally or improperly titled to a private individual or entity. The goal is to revert the land back to the public domain.
What is a Certificate of Ancestral Land Title (CALT)?	A CALT is a title issued by the NCIP to recognize the rights of indigenous peoples over their ancestral lands. It serves as proof of ownership and is based on the Indigenous Peoples Rights Act (IPRA).
What did the Supreme Court decide regarding jurisdiction?	The Supreme Court ruled that the RTC does have jurisdiction over reversion cases, even if the land in question is covered by a CALT. The Court reasoned that the action was aimed at reverting land to public domain, a matter within the RTC’s authority.
Why did the RTC initially dismiss the case?	The RTC initially dismissed the case, believing it lacked jurisdiction because the complaint challenged the validity of the NCIP’s decision to issue the CALT. The RTC thought it would be reviewing a decision of a co-equal body.
What is the role of the NCIP in land disputes?	The NCIP has jurisdiction over disputes involving the rights of Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs), provided that both parties are ICCs/IPs and have exhausted customary law remedies. However, it cannot rule on cases involving non-ICCs/IPs.
What was the basis for the Republic’s claim?	The Republic claimed that the land covered by the CALT was part of a government reservation (Baguio Stock Farm) and that the issuance of the CALT was irregular and violated IPRA provisions.
What is the significance of this Supreme Court decision?	This decision clarifies the jurisdiction of courts in land disputes involving ancestral land claims and public land reservations. It ensures that the government can protect public lands while also respecting the rights of indigenous peoples.
What was the outcome of the Petition-in-Intervention?	The Supreme Court denied the Petition-in-Intervention, ruling that the intervenors failed to prove a legal interest in the controversy and that the issue they raised (constitutionality of a provision in IPRA) was not the central issue of the case.

This Supreme Court decision provides important clarity on the jurisdiction of RTCs in reversion cases involving ancestral land titles. It balances the need to protect public lands with the recognition of indigenous rights, ensuring that all land disputes are resolved within the framework of the law. The ruling underscores the importance of due process and the right to seek redress in the courts, promoting fairness and equity in land ownership.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Republic vs. Heirs of Ikang Paus, G.R. No. 201273, August 14, 2019