Unduran v. Aberasturi
NEW DOCTRINEFacts
The Antecedents: Petitioners, members of the Talaandig tribe, claim ancestral ownership over land in Bukidnon. Respondents, claiming lawful ownership of an unregistered agricultural land (Lot No. 7367) within the same area, filed a complaint for accion reivindicatoria (recovery of ownership and possession) against the petitioners. The dispute centers on conflicting claims over this parcel of land. Procedural History: Respondents initially filed a complaint for accion reivindicatoria with damages. Petitioners moved to dismiss, arguing lack of jurisdiction due to the land being within ancestral domain and covered by a Certificate of Ancestral Domain Title (CADT). The National Commission on Indigenous Peoples (NCIP) also moved to refer the case to its Regional Hearing Office. Respondents then amended their complaint to one for injunction and damages. The Regional Trial Court (RTC) granted the amendment, denied the motion to refer, and declared most petitioners in default, also granting a writ of preliminary injunction. Petitioners elevated the matter to the Court of Appeals (CA), which affirmed the RTC's order but lifted the default order. The CA ruled that the RTC correctly retained jurisdiction and properly allowed the amendment. The Petition: Petitioners seek review on certiorari of the CA's decision, arguing that the CA erred in affirming the RTC's jurisdiction. They contend that the NCIP has exclusive and original jurisdiction over disputes involving ancestral domains, regardless of the nature of the action filed (e.g., injunction vs. accion reivindicatoria). Petitioners argue that the amendment of the complaint was a maneuver to confer jurisdiction on the RTC and that the CA erred in not recognizing the CADT's implications on jurisdiction. They assert that the subject matter inherently falls under the IPRA and thus the NCIP's exclusive purview.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over the amended complaint for injunction and damages involving an ancestral domain, considering the parties' ICC/IP affiliations and the nature of the dispute. Whether the CA erred in affirming the RTC's order allowing the amendment of the complaint to confer jurisdiction, given the requirements of Section 66 of the IPRA. Whether the CA erred in ruling that evidence must be presented before the RTC, and whether the existence of a CADT automatically divests the RTC of jurisdiction.
Ruling
The petition is denied. The Court of Appeals Decision dated August 17, 2006, and its Resolution dated July 4, 2007, are affirmed.
Ratio Decidendi
On the jurisdiction of the RTC over the amended complaint: The Court reiterated that jurisdiction is conferred by law and determined by the allegations in the complaint. The amended complaint was for injunction and damages (incapable of pecuniary estimation). The Court found that the allegations did not explicitly state that the parties were members of the same Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs) or that the case involved a dispute over ancestral lands/domains of ICCs/IPs. The NCIP's jurisdiction is generally limited to disputes arising between or among parties belonging to the same ICC/IP, due to the requirement of exhausting remedies under customary laws. When parties do not belong to the same ICC/IP, or one party is a non-ICC/IP, the case falls under the jurisdiction of the proper Courts of Justice, unless specific exceptions under the IPRA apply. In this case, the respondents did not belong to the same ICC/IP as the petitioners, thus, the RTC, not the NCIP, had jurisdiction. On the amendment of the complaint and the NCIP's jurisdiction: The Court found that the amendment of the complaint from accion reivindicatoria to injunction and damages was permissible. The mere fact that the case involved members of ICCs/IPs and their ancestral land does not automatically vest jurisdiction in the NCIP if the conditions under Section 66 of the IPRA are not met. The petitioners failed to establish that the respondents were not entitled to the relief prayed for, and the CA correctly lifted the order of default against some petitioners, allowing them to present their defense. On the ruling regarding evidence presentation and the effect of a CADT: The Court affirmed the CA's decision that the RTC had jurisdiction. The issue of whether evidence must be presented before the RTC was a consequence of the RTC's jurisdiction, which the CA upheld. The existence of a CADT does not automatically divest the RTC of jurisdiction, especially when the dispute involves parties from different ICC/IP affiliations or when one party is a non-ICC/IP.
Main Doctrine
The jurisdiction of the National Commission on Indigenous Peoples (NCIP) under Section 66 of the Indigenous Peoples' Rights Act (IPRA) is limited to claims and disputes involving rights of Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs) when they arise between or among parties belonging to the same ICC/IP. When such claims and disputes arise between or among parties who do not belong to the same ICC/IP, or where one of the parties is a non-ICC/IP, the case shall fall under the jurisdiction of the proper Courts of Justice, unless an exception under Sections 52, 62, or 54 of the IPRA applies.