TL;DR

The Supreme Court ruled that Baguio City is exempt from the Indigenous Peoples’ Rights Act (IPRA) concerning ancestral land titles due to Section 78 of IPRA, which respects Baguio City’s Charter and townsite reservation status. This means that the National Commission on Indigenous Peoples (NCIP) cannot issue ancestral land titles within Baguio City under IPRA. However, the ruling in Cariño v. Insular Government, which recognizes land ownership based on possession since time immemorial, still applies. In this specific case, the Carantes heirs’ claim for ancestral land titles in Baguio City was denied because they failed to prove continuous possession since time immemorial, and the land was within a forest reservation.

Upholding Townsite Reservations: Baguio City’s Unique Status Under IPRA

This case, Republic of the Philippines v. National Commission on Indigenous Peoples, revolves around the complex interplay between indigenous land rights and established townsite reservations, specifically in Baguio City. At its core, the Supreme Court grappled with whether the Indigenous Peoples’ Rights Act (IPRA) of 1997, a landmark law designed to protect the ancestral domains of indigenous communities, applies to Baguio City, given the city’s unique historical and legal context. The heirs of Lauro Carantes, claiming ancestral rights as Ibaloi indigenous people, sought Certificates of Ancestral Land Titles (CALTs) for parcels of land within Baguio City. This claim was initially granted by the NCIP, but the Republic challenged this decision, arguing that Baguio City is exempt from IPRA’s coverage due to Section 78 of the Act and the pre-existing Baguio Townsite Reservation.

The legal framework at the heart of this dispute includes the IPRA, particularly Section 78, which 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: Provided, further, That this provision shall not apply to any territory which becomes part of the City of Baguio after the effectivity of this Act.

The Republic argued that this section explicitly exempts Baguio City from IPRA’s ancestral domain provisions, emphasizing the Baguio Townsite Reservation established in 1907 and the General Land Registration Office (GLRO) Record No. 211, which declared most lands within the reservation as public lands unless claimed and adjudicated as private property within a specific period. The Court of Appeals, however, sided with the NCIP and the Carantes heirs, citing previous jurisprudence that suggested Section 78 merely acknowledges prior land rights without exempting Baguio City from IPRA altogether.

The Supreme Court, in reversing the Court of Appeals, firmly declared that Section 78 of IPRA indeed exempts Baguio City from the law’s coverage regarding ancestral land titles. The Court emphasized the explicit language of Section 78, underscoring that Baguio City remains governed by its Charter and its townsite reservation status persists until legislative reclassification. This interpretation aligns with the legislative intent behind IPRA, as evidenced by congressional deliberations indicating a desire to maintain Baguio City’s distinct land administration framework. The Court reiterated its stance from Republic v. National Commission on Indigenous Peoples (2019), which definitively stated that NCIP lacks the authority to issue ancestral titles within Baguio Townsite Reservation unless Congress reclassifies the land.

However, the Supreme Court clarified that while IPRA’s ancestral domain provisions do not apply in Baguio City, this does not negate all forms of indigenous land ownership recognition. The Court explicitly invoked the landmark case of Cariño v. Insular Government (1909), a cornerstone of Philippine jurisprudence concerning native title. Cariño established the principle that land occupied and possessed by Filipinos since time immemorial is presumed to be private land, never to have been public land. This doctrine operates independently of IPRA and remains applicable nationwide, including Baguio City. Therefore, indigenous claimants in Baguio City, like the Carantes heirs, are not entirely without recourse. They can still pursue land ownership claims based on the Cariño doctrine by demonstrating continuous occupation and possession of the land since time immemorial.

In the Carantes case, despite acknowledging the applicability of Cariño, the Supreme Court ultimately denied their claim. The Court found that the Carantes heirs failed to sufficiently prove actual, continuous possession of the claimed land since time immemorial. Evidence indicated that the land was within the Forbes Forest Reservation and occupied by entities like Camp John Hay and Baguio Country Club, predating IPRA. Thus, while the door to asserting native title under Cariño remains open even in Baguio City, the burden of proof to establish immemorial possession is substantial and was not met in this instance. The decision underscores a balanced approach: IPRA’s specific ancestral domain mechanisms are inapplicable in Baguio City due to its unique legal history, but the fundamental right to claim ownership based on time immemorial possession, as recognized in Cariño, persists as a vital legal avenue for indigenous communities even within the city’s reservations.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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.
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