Galang v. Wallis
REITERATIONFacts
The Antecedents: Petitioners filed a Complaint for Accion Reivindicatoria, Declaration of Nullity of PSU No. 203172, Annulment of Tax Declaration, Injunction with Prayer for Temporary Restraining Order (TRO) and Damages, claiming ownership of parcels of land in Ampucao, Itogon, Benguet. They traced their title to Wasiwas Bermor, who occupied the land since 1908 and registered it in 1961. Petitioner Brenda Fagyan acquired the land from Bermor via a Deed of Absolute Sale dated September 13, 1973, and subsequently divided and transferred portions to other petitioners. Petitioners alleged that respondents were intruding into their land in bad faith and without color of title, using fraudulently acquired documents, specifically Tax Declaration No. 2010-01-09-02350 and PSU No. 203172. Procedural History: Respondents moved to dismiss, arguing that the Regional Trial Court (RTC) lacked jurisdiction because the land is ancestral and the dispute is among indigenous peoples, thus falling under the exclusive jurisdiction of the NCIP. They presented a Resolution granting an application for recognition of ancestral land in favor of the Heirs of Toato Bugnay. The RTC dismissed the complaint, citing Sections 66 of Republic Act (R.A.) No. 8371 (Indigenous Peoples' Rights Act of 1997 or IPRA) and Section 5, Rule III of NCIP Administrative Circular No. 1-03, which grant the NCIP exclusive jurisdiction over such disputes. The RTC also invoked the doctrine of primary jurisdiction. The RTC denied petitioners' Motion for Reconsideration. The Petition: Petitioners sought review, arguing that the RTC erred in dismissing the case for lack of jurisdiction. They contended that the NCIP's jurisdiction under Section 66 of IPRA is limited to disputes between members of the same ICC/IP group, and that this case involves parties from different groups or non-IP members. They asserted that their complaint is an accion reivindicatoria, a civil action within the RTC's jurisdiction, and that an ancestral land registration action does not preclude an accion reivindicatoria.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over the complaint for accion reivindicatoria and other civil reliefs, despite the subject land being allegedly ancestral and the parties being indigenous peoples; and whether the National Commission on Indigenous Peoples (NCIP) has exclusive jurisdiction over the dispute. Whether the petitioners' complaint alleged an accion reivindicatoria, a civil action involving an interest in real property with an assessed value exceeding ₱20,000.00, which falls squarely within the jurisdiction of the RTC; whether the present controversy involves specific matters such as adverse claims and border disputes arising from delineation of ancestral domains/lands, cancellation of fraudulently issued Certificates of Ancestral Domain Title, and disputes and violations of ICC/IP's rights between members of the same ICC/IP group; and whether the pronouncement in The City Government of Baguio City, et al. v. Atty. Masweng, et al. regarding the NCIP's jurisdiction over disputes where one party is not an ICC/IP was merely an obiter dictum.
Ruling
The petition is GRANTED. The assailed Orders of the RTC dated August 27, 2015, and February 8, 2016, are REVERSED and SET ASIDE. The case is REMANDED to the RTC for further proceedings and proper disposition on the merits.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the RTC erred in dismissing the complaint for lack of jurisdiction. The jurisdiction of the NCIP, as provided under Section 66 of R.A. No. 8371 (IPRA), is limited to claims and disputes involving the rights of Indigenous Cultural Communities (ICCs)/Indigenous Peoples (IPs) that arise between or among parties belonging to the same ICC/IP group. This limitation is due to the proviso in Section 66 requiring exhaustion of remedies under customary laws, which cannot be complied with if parties belong to different ICC/IP groups or if one party is a non-ICC/IP member. In such scenarios, the regular courts, including the RTC, possess jurisdiction. The Court reiterated its ruling in Unduran, which clarified the limited jurisdiction of the NCIP. In the present case, the parties do not belong to the same ICC/IP group, and some are not even ICC/IP members at all. Therefore, even if the subject land is ancestral, the dispute falls within the jurisdiction of the RTC, not the NCIP. The Court emphasized that the petitioners' complaint alleged an accion reivindicatoria, a civil action involving an interest in real property with an assessed value exceeding ₱20,000.00, which falls squarely within the jurisdiction of the RTC. The complaint did not explicitly allege that the parties were members of the same ICC/IP or that the dispute was over the ancestral land of a specific ICC/IP. The Court clarified that the NCIP's primary jurisdiction, regardless of party affiliation, is limited to specific matters such as adverse claims and border disputes arising from delineation of ancestral domains/lands, cancellation of fraudulently issued Certificates of Ancestral Domain Title, and disputes and violations of ICC/IP's rights between members of the same ICC/IP group. The present controversy does not involve these matters. The Court distinguished the present case from The City Government of Baguio City, stating that any pronouncement in that case regarding the NCIP's jurisdiction over disputes where one party is not an ICC/IP was merely an obiter dictum (a statement of opinion not essential to the decision) and thus, without binding force.
Main Doctrine
The National Commission on Indigenous Peoples (NCIP) has jurisdiction over claims and disputes involving rights of Indigenous Cultural Communities (ICCs)/Indigenous Peoples (IPs) only when they arise between or among parties belonging to the same ICC/IP group. When such claims and disputes arise between or among parties who do not belong to the same ICC/IP group, or when one party is not an ICC/IP member, the regular courts have jurisdiction, even if the subject land is ancestral land.