Heirs of Pineda v. Office of the President
REITERATIONFacts
The Antecedents: Aida Pineda (Pineda) filed an application for ancestral land claim in Baguio City in 1991, pursuant to DENR Special Order No. 31, series of 1990. The survey conducted in 1991 indicated the area claimed was a portion of Lot No. 1, PSU-223647, surveyed for Teofilo Pilando, Sr. (Pilando). In 1993, the DENR issued four Certificates of Ancestral Land Claim (CALC) in favor of Pineda. Procedural History: The Heirs of Teofilo Pilando, Sr. (Heirs of Pilando) filed a Petition for Annulment of the CALCs in 1996, claiming prior right traced from Pilando, who allegedly purchased the land in 1956 or 1957, caused its survey in 1966, and declared it for tax purposes since 1967. The DENR, in 2007, ordered the recall of Pineda's CALCs and segregation of the Heirs of Pilando's claim, finding that the Heirs of Pilando established a prior right as long-time occupants. The Office of the President, in 2011, affirmed the DENR ruling, holding that the CALCs had no legal basis and that the Heirs of Pilando acquired a right to government grant due to open, continuous, exclusive, and notorious possession. The Court of Appeals, in 2015, affirmed the decisions of the OP and DENR, stating that the CALCs were provisional and Baguio City's exemption from IPRA was clear, and that the DENR had primary administrative jurisdiction. The CA denied the motion for reconsideration in 2016. The Petition: The Heirs of Pineda filed a Petition for Review on Certiorari, assailing the CA's decision. They argued that the CA ruled contrary to City Government of Baguio v. Atty. Masweng, that Baguio City's exemption from IPRA cannot be deduced from the Act itself, and that they were disregarded of their native title despite sufficient evidence of possession and ownership.
Issue(s)
Whether the Court of Appeals erred in affirming the decisions of the Department of Environment and Natural Resources and the Office of the President recalling the Certificates of Ancestral Land Claim issued in favor of petitioners; specifically, whether the IPRA applies to Baguio City and whether the CALCs qualify as valid prior land rights. Whether petitioners established a valid prior land right or native title over the subject properties in Baguio City, considering the limited rights conferred by a CALC and the evidence presented regarding prior possession and acquisition.
Ruling
The Court denies the Petition. It affirms the June 23, 2015 Decision and March 2, 2016 Resolution of the Court of Appeals in CA-G.R. SP No. 128152.
Ratio Decidendi
On the first issue: The Court held that Section 78 of the Indigenous Peoples' Rights Act of 1997 (IPRA) expressly excludes the City of Baguio from its application, mandating that Baguio City shall remain governed by its own charter. While the IPRA recognizes prior land rights and titles acquired before its effectivity, a Certificate of Ancestral Land Claim (CALC) by itself does not qualify as such a valid prior land right or title. The CALCs issued to petitioners were considered provisional and issued in anticipation of the IPRA, which did not apply to Baguio City. Furthermore, the DENR had primary administrative jurisdiction over the cancellation petition at the time of filing, and the petitioners failed to prove grave abuse of discretion on the part of the Office of the President. The factual findings of the DENR, affirmed by the OP and CA, were accorded great respect. On the second issue: The Court reiterated that Baguio City is governed by its charter, and while Section 78 of IPRA concedes the validity of prior land rights recognized or acquired before its effectivity, the CALCs issued to petitioners were not conclusive titles. Citing Philippine Economic Zone Authority v. Borreta and Philippines Economic Zone Authority v. Carantes, the Court clarified that holders of a CALC possess limited rights, primarily for occupation and cultivation, and not ownership. Petitioners failed to establish that their rights were validly recognized in any administrative or judicial proceedings prior to IPRA's effectivity. They did not provide evidence of how their predecessors-in-interest acquired the lots or the duration of their possession. Moreover, the expansion of the claimed area from 49,645 square meters to 61,673 square meters for the CALCs was noted as an issue, similar to cases where expanded areas were invalidated.
Main Doctrine
A Certificate of Ancestral Land Claim, by itself, does not qualify as a valid prior land right and title over ancestral land, especially when the land is located in Baguio City, which is expressly excluded from the application of the Indigenous Peoples' Rights Act and governed by its own charter, unless such prior land rights were validly acquired through judicial, administrative, or other processes before the Act's effectivity.