Republic v. Heirs of Paus
REITERATIONFacts
The Antecedents: The Heirs of Ikang Paus (private respondents) filed a petition with the National Commission on Indigenous Peoples (NCIP) for the identification, delineation, and issuance of a Certificate of Ancestral Land Title (CALT) over a large parcel of land. The Heirs of Mateo Cariño opposed this petition. The NCIP issued Resolution No. 060-2009, declaring the land as ancestral land belonging to the Heirs of Ikang Paus and ordering the issuance of two Certificates of Ancestral Land Title (CALT). Consequently, Original Certificate of Title (OCT) No. 0-CALT-37 was issued in the name of the private respondents. The Heirs of Mateo Cariño's motion for reconsideration was denied. Procedural History: The Republic of the Philippines, through the Office of the Solicitor General (OSG), filed a Complaint for Reversion, Annulment of Documents, and Cancellation of Title with a prayer for TRO and preliminary injunction, questioning the issuance of OCT No. 0-CALT-37 due to alleged irregularities. The private respondents argued that the Regional Trial Court (RTC) lacked jurisdiction, asserting that the matter fell under the exclusive jurisdiction of the NCIP. The RTC, agreeing with the private respondents, dismissed the Republic's complaint for lack of jurisdiction. The Republic filed a petition for certiorari with the Court of Appeals (CA), which affirmed the RTC's dismissal. The Republic then filed a petition for review on certiorari with the Supreme Court. The Petition: The Republic assails the CA's decision, arguing that the RTC, in the exercise of its original and exclusive jurisdiction over titles to property, has the power to examine decisions of co-equal bodies like the NCIP if they are patently null and void. The Republic contends that the RTC may refuse to recognize the validity of such decisions and that a petition for certiorari was the proper remedy, even as a non-party to the NCIP proceedings.
Issue(s)
Whether the RTC, in the exercise of its original and exclusive jurisdiction over titles to property, has the power and authority to examine the decision or resolution of a co-equal body such as the NCIP to the extent that they are patently null and void ab initio for the purpose of annulling an OCT issued based on said decision or resolution; and whether the RTC, in the exercise of its original and exclusive jurisdiction over titles to property, may refuse to recognize the validity of a decision or resolution of a co-equal body if it finds the same to be patently null and void. Whether a petition for certiorari is the proper remedy to assail a null and void NCIP resolution and whether or not said remedy is applicable in the petitioner's case where it is not a party to the proceedings of said resolution. Whether it is proper for the Court to decide on the substantive merits of the nine (9) causes of action raised by petitioner in its complaint filed before the RTC assailing NCIP En Banc Resolution No. 060-2009-AL, Series of 2009.
Ruling
The Supreme Court ruled that the RTC committed grave abuse of discretion in dismissing the Republic's Complaint for lack of jurisdiction. The Court found that the complaint was essentially for reversion and cancellation of a Torrens title, which falls within the exclusive original jurisdiction of the RTC. The Court reversed and set aside the CA's decision, remanding the case to the RTC for trial on the merits. The Petition-in-Intervention of the Heirs of Mateo Cariño and Bayosa Ortega was denied for lack of merit.
Ratio Decidendi
On the RTC's and NCIP's Jurisdiction: The Court held that the RTC has jurisdiction over actions for reversion and cancellation of certificates of title. The nature of an action is determined by the material allegations of the complaint and the character of the relief sought. The Republic's complaint alleged that OCT No. 0-CALT-37 was issued over land of the public domain, specifically within the Baguio Stock Farm (BSF), which was reserved for animal breeding purposes. The complaint sought the nullification and cancellation of the OCT and CALT, and the survey plan, arguing that these should not have been issued over government land. This squarely constitutes a complaint for reversion of land to the public domain and cancellation of a Torrens title, matters within the exclusive original jurisdiction of the RTC under Batas Pambansa Blg. 129. The RTC's dismissal for lack of jurisdiction was a grave abuse of discretion, as it refused to perform a duty enjoined by law. The Court clarified that the NCIP's jurisdiction is limited to claims and disputes involving the rights of Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs), provided that customary laws have been exhausted. The NCIP does not have jurisdiction over controversies involving non-ICCs/IPs, such as the Republic, the Register of Deeds, and the Land Registration Authority, even if the dispute involves the rights of ICCs/IPs. Such disputes must be brought before a court of general jurisdiction. Therefore, the RTC and CA erred in treating the Republic's complaint as an appeal from an NCIP resolution, as the NCIP could not have had jurisdiction over the subject matter in the first place due to the involvement of non-ICCs/IPs. On the Propriety of Certiorari and Non-Party Status: The Court found that the Republic's resort to a petition for certiorari under Rule 65 was procedurally correct in assailing the RTC's dismissal for grave abuse of discretion. While the Republic was not a party to the NCIP proceedings, its cause of action arose from the issuance of the OCT, which it sought to nullify. The Republic's claim that the CALT and OCT were null and void ab initio because they covered public land, which is non-registrable, allowed it to attack these titles directly or collaterally, irrespective of its status as a party to the NCIP proceedings. The RTC's dismissal for lack of jurisdiction prevented the Republic from seeking any remedy, thus justifying the use of certiorari. On Ruling on Substantive Merits and the Petition-in-Intervention: The Court deemed it premature to rule on the nine causes of action raised by the Republic in its complaint. Such a determination would require the presentation and reception of evidence, which is a function of the trial court, not the Supreme Court in a petition for review on certiorari. The Court's role was to determine the jurisdictional issue, not to try the case on the merits. Therefore, the case was remanded to the RTC for further proceedings. The Petition-in-Intervention filed by the Heirs of Mateo Cariño and Bayosa Ortega was denied for lack of merit. They failed to demonstrate a legal interest in the controversy, which primarily concerned the jurisdiction of the RTC over the Republic's complaint. Their attempt to have Section 53 of the Indigenous Peoples Rights Act (IPRA) declared unconstitutional was not the lis mota of the case and would unduly delay its adjudication. The Court reiterated that it generally avoids ruling on constitutional questions if the case can be resolved on other grounds.
Main Doctrine
The Regional Trial Court (RTC) has jurisdiction over complaints for reversion and cancellation of titles, even if these actions necessitate the examination of decisions or resolutions of quasi-judicial bodies like the National Commission on Indigenous Peoples (NCIP), particularly when the validity of a Torrens title issued based on such resolutions is questioned. The NCIP's jurisdiction is limited to disputes involving Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs) and does not extend to controversies involving non-ICCs/IPs, which fall under the purview of courts of general jurisdiction.