In a dispute over ancestral land in Baguio City, the Supreme Court affirmed that while the Indigenous Peoples’ Rights Act (IPRA) recognizes ancestral land claims, it specifically excludes Baguio City from its full application. The Court ruled that prior land rights and titles, validly acquired before IPRA’s effectivity, are respected, but a Certificate of Ancestral Land Claim (CALC) alone does not establish such a prior right. This decision underscores the importance of adhering to Baguio City’s charter and the need for concrete evidence of ownership predating IPRA’s enactment.

Baguio Land Dispute: Whose Claim Prevails Under IPRA and the City Charter?

The case revolves around conflicting claims to a parcel of land in Baguio City. The Heirs of Aida Pineda (petitioners) based their claim on Certificates of Ancestral Land Claim (CALCs) issued in their favor in 1993. Opposing them were the Heirs of Teofilo Pilando, Sr. (respondents), who asserted prior rights dating back to a purchase made by their ancestor in the 1950s, coupled with continuous possession and tax declarations. The legal question before the Supreme Court was whether the CALCs issued to the petitioners were valid and should prevail over the respondents’ claim of prior rights.

The legal framework governing this case is complex, involving the interplay between the Indigenous Peoples’ Rights Act (IPRA) and the specific provisions of Baguio City’s charter. Section 78 of IPRA contains a special provision that excludes Baguio City from the general application of the Act. This provision states:

SECTION 78. Special Provision. — 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: Provided, That prior land rights and titles recognized and/or acquired through any judicial, administrative or other processes before the effectivity of this Act shall remain valid…

This exclusion means that while IPRA generally recognizes and protects the rights of indigenous peoples to their ancestral lands, Baguio City operates under its own set of rules, primarily its charter. However, the proviso in Section 78 acknowledges that any land rights or titles that were already recognized or acquired before IPRA came into effect should still be considered valid. Building on this principle, the court has consistently held that Baguio City’s charter governs the determination of land rights within the city, as highlighted in Republic v. National Commission on Indigenous Peoples, which firmly stated that RA 8371 is clear that, for properties part of the townsite reservation of Baguio City before the passage of the IPRA, no new CALT or CADT can be issued by the NCIP.

The Department of Environment and Natural Resources (DENR) and the Office of the President (OP) both ruled against the Heirs of Pineda, ordering the recall of their CALCs. These decisions were based on the finding that the CALCs were issued without proper legal basis, especially considering Baguio City’s exclusion from the main provisions of IPRA. The Court of Appeals (CA) affirmed these rulings, emphasizing that the CALCs were merely provisional and did not confer permanent rights, given the explicit exclusion of Baguio City from IPRA’s scope. The CA also noted that the DENR had primary administrative jurisdiction over the case at the time of filing. Ultimately, this position contrasts sharply with arguments suggesting that IPRA should have full force within Baguio City, irrespective of Section 78.

The Supreme Court’s decision hinged on the interpretation of Section 78 of IPRA and the nature of the CALCs held by the petitioners. The Court emphasized that while IPRA recognizes prior land rights, the CALCs, by themselves, do not qualify as such rights. A crucial aspect of the Court’s reasoning was the distinction between a Certificate of Ancestral Land Claim (CALC) and a Certificate of Ancestral Land Title (CALT). As previously stated in Philippine Economic Zone Authority v. Borreta, the Court noted that a CALC represents a mere application for ownership and does not confer vested rights of ownership. The Court reinforced this view, stating that holders of a CALC have limited rights, primarily related to occupation and cultivation, but not the right to build permanent structures or exercise full ownership, which is reserved for those with a CALT.

Moreover, the Court addressed the petitioners’ argument that they possessed native title over the land, which should be protected under IPRA. The Court referenced the landmark case of Cariño v. Insular Government, which recognized the validity of native title based on long-standing occupation and claim of private ownership. However, the Court found that the petitioners failed to provide sufficient evidence to establish their claim of native title. This approach contrasts with arguments that rely solely on the issuance of a CALC as sufficient proof of ancestral land rights, without substantiating historical occupation and ownership.

The Court also pointed out a significant discrepancy in the petitioners’ claim. While their initial application in 1991 was for 49,645 square meters, the CALCs issued covered an expanded area of 61,673 square meters. This unexplained expansion raised concerns about the legitimacy of the claim, echoing the Court’s caution in Presidential Decree No. 1271 Committee v. De Guzman against unscrupulous parties manipulating land titles in Baguio City. Given these considerations, the Supreme Court ultimately sided with the Heirs of Pilando, affirming the decisions of the lower bodies. This decision reinforces the principle that claims to ancestral land in Baguio City must be supported by concrete evidence of prior rights and titles, predating the effectivity of IPRA.

The practical implications of this decision are significant for individuals and communities in Baguio City claiming ancestral land rights. It clarifies that simply holding a CALC is not enough to establish ownership or prior rights. Claimants must demonstrate that their rights were recognized or acquired through judicial, administrative, or other processes before IPRA’s enactment. Furthermore, the decision highlights the importance of complying with Baguio City’s charter and other relevant laws governing land ownership and registration. For example, a claimant must have registered their land rights within the period stated in the Land Registration Act.

FAQs

This Supreme Court decision serves as a crucial reminder of the complexities surrounding ancestral land claims in Baguio City. While IPRA aims to protect the rights of indigenous peoples, its application in Baguio City is limited by Section 78, which gives primacy to the city’s charter. Claimants must provide concrete evidence of prior rights to secure their claims. This decision highlights the importance of consulting with legal experts and gathering comprehensive documentation to support any ancestral land claim in Baguio City.

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: HEIRS OF AIDA PINEDA VS. OFFICE OF THE PRESIDENT, G.R. No. 223808, April 26, 2023

This Supreme Court decision clarifies the interplay between the Indigenous Peoples’ Rights Act (IPRA) and the Baguio City Charter concerning ancestral land claims. The Court affirmed that while IPRA generally does not apply to Baguio City, prior land rights validly acquired before IPRA’s enactment are still recognized. The case underscores that a Certificate of Ancestral Land Claim (CALC) alone does not establish valid prior land right or title, highlighting the necessity for claimants to demonstrate legally recognized rights predating IPRA’s effectivity. This ruling emphasizes the importance of adhering to established legal processes for land ownership in Baguio City, ensuring that historical claims are balanced with existing legal frameworks.

Baguio Land Dispute: Can Ancestral Claims Override City Governance?

The case of Heirs of Aida Pineda vs. Office of the President revolves around a contested land claim in Baguio City. Petitioners, the Heirs of Aida Pineda, sought to assert their rights over a parcel of land based on Certificates of Ancestral Land Claim (CALCs) issued in their favor. These certificates were granted before the enactment of the Indigenous Peoples’ Rights Act (IPRA). The respondents, the Office of the President, the Department of Environment and Natural Resources (DENR), and the Heirs of Teofilo Pilando, Sr., challenged the validity of these CALCs. They argued that Baguio City is explicitly excluded from IPRA’s coverage and that the Pilando heirs possessed prior rights to the land. The central legal question is whether the CALCs, issued before IPRA, could establish a valid claim to ancestral land in Baguio City, despite the city’s exclusion from the Act.

The roots of the dispute trace back to 1991 when Aida Pineda applied for an ancestral land claim over approximately 49,645 square meters in Baguio City. This application was made under DENR Special Order No. 31, series of 1990, which aimed to process ancestral land claims in the Cordillera Administrative Region. Subsequently, in 1993, the DENR issued four CALCs in favor of Pineda, covering 61,673 square meters. However, in 1996, the Heirs of Teofilo Pilando, Sr. filed a Petition for Annulment of the CALCs, asserting a prior right based on their predecessor’s long-term occupation and improvements on the land. This claim originated from Teofilo Pilando, Sr.’s purchase of the land in the 1950s, his subsequent survey, and tax declarations.

The DENR, in its 2007 decision, ordered the recall of the CALCs issued to Pineda, emphasizing that the Special Task Force’s recommendations were not binding, especially considering Baguio City’s exclusion from IPRA. The Office of the President affirmed this decision in 2011, stating that the CALCs lacked legal basis, both before and after IPRA’s enactment. This decision underscored that the Pilando heirs had acquired a right to government grant due to their continuous possession and occupation of the land. The Court of Appeals upheld these rulings, reinforcing the provisional nature of the CALCs and the DENR’s administrative jurisdiction over the matter. Thus, the Heirs of Pineda elevated the case to the Supreme Court, arguing that Baguio City’s exemption from IPRA should not negate their native title over the ancestral land.

The Supreme Court anchored its decision on Section 78 of IPRA, which explicitly excludes Baguio City from the Act’s application. This provision mandates that Baguio City remains governed by its Charter, and lands proclaimed as part of its townsite reservation retain that status until reclassified by appropriate legislation. The Court, citing Republic v. National Commission on Indigenous Peoples, emphasized that Section 78 provides specific guidelines for land rights within Baguio City. These include recognizing prior land rights and titles acquired through judicial, administrative, or other processes before IPRA’s effectivity, and exempting territories that became part of Baguio City after IPRA’s enactment. This framework clearly delineates that IPRA does not generally authorize the NCIP to issue ancestral land titles within Baguio City, except under specific conditions.

Building on this principle, the Court addressed the validity of the Certificates of Ancestral Land Claim held by the petitioners. Citing Philippine Economic Zone Authority v. Borreta, the Court reiterated that a CALC does not confer vested ownership rights. It merely acknowledges the claimant’s right to occupy and cultivate the land, subject to existing laws and regulations. Moreover, the Court referenced Philippines Economic Zone Authority v. Carantes, outlining the limited rights of CALC holders, primarily focusing on occupation for cultivation rather than the right to build permanent structures or exercise full ownership. These precedents establish that a CALC, by itself, does not equate to a recognized title or right that supersedes existing legal frameworks governing land ownership.

This approach contrasts with the petitioners’ argument that their CALCs establish prior land rights protected under Section 78 of IPRA. The Court clarified that the Special Task Force, which issued the CALCs, was organized to prepare for the anticipated enactment of IPRA. The certificates were intended to be provisional, pending the passage of enabling legislation. The petitioners were still required to convert these CALCs to Certificates of Ancestral Land Title (CALTs) under the guidelines of NCIP Administrative Order No. 2-02. However, they failed to complete this conversion, thus weakening their claim to a legally recognized title. The decision underscores the necessity for claimants to demonstrate a clear legal basis for their land rights that predates IPRA’s enactment.

The Court further addressed the petitioners’ claim of native title, a concept rooted in the long-term occupation and use of land since time immemorial. While acknowledging the principle established in Cariño v. Insular Government, which recognized the validity of native title, the Court emphasized the need for concrete evidence to support such claims. The case of Republic v. National Commission on Indigenous Peoples elucidated the governing law for prior land rights in Baguio City, referencing Act No. 926 and Act No. 627, which mandated the registration of land titles within a specified period. Failure to comply with these registration requirements resulted in the barring of land rights. In this context, the Court found that the petitioners failed to provide sufficient evidence that their rights over the properties were validly recognized in any administrative or judicial proceedings before IPRA’s effectivity.

Ultimately, the Supreme Court underscored that it is not a trier of facts and will generally defer to the factual findings of lower courts, especially when supported by substantial evidence. The petitioners’ invitation to the Court to re-evaluate the evidence was declined, as they failed to demonstrate a clear case warranting a factual review. The Court emphasized that the burden of proving prior and preeminent right over the land rests on the petitioners, a burden they failed to discharge. Thus, the Court affirmed the decisions of the Court of Appeals, the Office of the President, and the DENR, effectively denying the Heirs of Aida Pineda’s claim to ancestral land in Baguio City.

FAQs

This case underscores the complexities of land ownership disputes in Baguio City, particularly those involving ancestral land claims. The Supreme Court’s decision highlights the importance of adhering to established legal processes and demonstrating legally recognized rights predating the enactment of the Indigenous Peoples’ Rights Act. Moving forward, individuals and communities seeking to assert ancestral land rights in Baguio City must present comprehensive evidence of prior valid titles or rights, ensuring compliance with relevant laws and regulations.

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: HEIRS OF AIDA PINEDA VS. OFFICE OF THE PRESIDENT, G.R. No. 223808, April 26, 2023