The Supreme Court held that Regional Trial Courts (RTCs), sitting as special environmental courts, have jurisdiction over cases involving violations of environmental laws affecting ancestral lands, particularly when the dispute involves non-Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs). This decision clarifies that the National Commission on Indigenous Peoples (NCIP) has limited jurisdiction, primarily handling disputes among ICCs/IPs. The ruling ensures that environmental concerns within ancestral domains are addressed through the proper legal channels, protecting the rights of indigenous communities while upholding environmental regulations. It underscores the importance of correctly identifying the nature of the action based on the complaint’s allegations to determine the appropriate jurisdiction.

Bulldozers vs. Ibaloi Heritage: Who Decides the Fate of Ancestral Lands?

This case revolves around a dispute between the heirs of Tunged, representing the Ibaloi tribe, and Sta. Lucia Realty and Development, Inc., and Baguio Properties, Inc. The heirs claimed that the respondents’ earthmoving activities on their ancestral land violated their rights under the Indigenous Peoples Rights Act (IPRA) and environmental laws. They filed a complaint with the Regional Trial Court (RTC) sitting as an environmental court, seeking an Environmental Protection Order and recognition of their rights. The RTC dismissed the case, asserting it lacked jurisdiction and that the matter fell under the NCIP’s purview. The central legal question is whether the RTC erred in dismissing the case, given the allegations of environmental violations and the involvement of non-IP parties.

The Supreme Court’s analysis hinged on determining the correct jurisdiction based on the allegations in the complaint. It emphasized that jurisdiction is conferred by law and determined by the nature of the action pleaded, irrespective of whether the plaintiff is ultimately entitled to recover. The Court cited its previous ruling in Unduran, et al. v. Aberasturi, et al., which clarified that the NCIP’s jurisdiction is limited to claims and disputes arising between parties belonging to the same ICC/IP. According to the court:

[J]urisdiction over the subject matter of a case is conferred by law and determined by the allegations in the complaint which comprise a concise statement of the ultimate facts constituting the plaintiffs cause of action. The nature of an action, as well as which court or body has jurisdiction over it, is determined based on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein. The averments in the complaint and the character of the relief sought are the ones to be consulted. Once vested by the allegations in the complaint, jurisdiction also remains vested irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein.

Building on this principle, the Court examined Section 66 of the IPRA, which outlines the NCIP’s jurisdiction. It noted that the NCIP’s authority extends to disputes involving rights of ICCs/IPs, provided that the parties have exhausted all remedies under their customary laws. The court also referenced Administrative Order (AO) No. 23-2008, which designated the RTC as a special court to hear violations of environmental laws. The Supreme Court emphasized that the allegations in the complaint, including the claim of ancestral land ownership, the respondents’ earthmoving activities, and the violation of the Environmental Compliance Certificate (ECC), were crucial in determining jurisdiction.

The Supreme Court scrutinized the reliefs prayed for by the petitioners, which included an Environmental Protection Order, recognition of their rights as IPs, and restoration of the denuded areas. Based on these allegations and prayers, the Court concluded that the RTC, sitting as a special environmental court, had jurisdiction over the case. The Court found that the RTC erred in ruling that the NCIP had jurisdiction because the respondents were non-ICCs/IPs. The Supreme Court quoted the following from Unduran:

A careful review of Section 66 shows that the NCIP shall have jurisdiction over claims and disputes involving rights of ICCs/IPs only when they arise between or among parties belonging to the same ICC/IP.

This clarified that disputes involving non-ICCs/IPs fall under the jurisdiction of the regular courts. Furthermore, the Court emphasized that the case was not an action for the claim of ownership or an application for CALTs/CADTs, distinguishing it from matters falling under the NCIP’s exclusive domain. Therefore, the court held that the petitioners’ cause of action, grounded on environmental violations and rights under the IPRA and PD 1586, was within the RTC’s jurisdiction as a special environmental court.

The Court further reasoned that the petitioners had established sufficient locus standi to institute the action. They supported their allegations with documents, including the NCIP’s report and recommendation on their pending petition for CALTs. This report acknowledged the petitioners as heirs of Tunged and recognized their possession and occupation of the subject land. Consequently, the Court determined that the RTC’s dismissal of the case for lack of legal personality was erroneous.

Even if the case were not within the RTC’s jurisdiction as an environmental court, the Supreme Court noted that outright dismissal was not the proper course of action. Section 3, Rule 2 of A.M. No. 09-6-8-SC mandates that if a complaint is not an environmental complaint, the presiding judge should refer it to the executive judge for re-raffle to the regular court. This provision ensures that cases are properly adjudicated, even if initially misfiled in the wrong court. Consequently, the Supreme Court granted the petition, nullified the RTC’s orders, and reinstated the case for proper disposition.

FAQs

What was the key issue in this case?	The key issue was whether the Regional Trial Court (RTC) erred in dismissing the case for lack of jurisdiction, asserting that the National Commission on Indigenous Peoples (NCIP) should handle the dispute. The Supreme Court ultimately addressed the jurisdictional boundaries between the RTC and NCIP in cases involving ancestral land rights and environmental law violations.
Who are the parties involved in this case?	The petitioners are the Heirs of Tunged, representing the Ibaloi tribe, who claim ancestral rights over the disputed land. The respondents are Sta. Lucia Realty and Development, Inc., a real estate developer, and Baguio Properties, Inc., which manages the properties involved.
What laws are relevant to this case?	The relevant laws include the Indigenous Peoples Rights Act (IPRA), Presidential Decree (PD) No. 1586 (establishing the Environmental Impact Statement System), and Administrative Matter (AM) No. 09-6-8-SC (Rules of Procedure for Environmental Cases). Batas Pambansa Blg. (BP) 129 (Reorganizing the Judiciary) is also relevant.
What is the jurisdiction of the NCIP?	The NCIP has jurisdiction over claims and disputes involving rights of ICCs/IPs, but only when the disputes arise between parties belonging to the same ICC/IP. When disputes involve non-ICCs/IPs, the case falls under the jurisdiction of the regular courts.
What was the basis of the petitioners’ complaint?	The petitioners’ complaint was based on the respondents’ earthmoving activities on their ancestral land, which they claimed violated their rights under the IPRA and environmental laws. They also alleged violations of the Environmental Compliance Certificate (ECC) issued to the respondents.
Why did the RTC initially dismiss the case?	The RTC dismissed the case for lack of jurisdiction, reasoning that the recognition of the petitioners’ rights as IPs was not the proper subject of an environmental case and should be addressed through the IPRA. The RTC also stated that the petitioners lacked legal personality since their rights were not yet formally recognized.
What did the Supreme Court decide?	The Supreme Court reversed the RTC’s decision, holding that the RTC, sitting as a special environmental court, had jurisdiction over the case. The Court emphasized that the allegations in the complaint, including environmental violations and rights under the IPRA, placed the case within the RTC’s jurisdiction.
What is the significance of the Unduran v. Aberasturi case in this decision?	The Supreme Court cited the Unduran v. Aberasturi case to clarify the jurisdictional boundaries of the NCIP. It reiterated that the NCIP’s jurisdiction is limited to disputes among members of the same ICC/IP, and disputes involving non-ICCs/IPs fall under the jurisdiction of the regular courts.

This Supreme Court decision provides important clarity on the jurisdictional issues surrounding ancestral land rights and environmental law violations. It reinforces the principle that environmental concerns affecting indigenous communities are to be addressed through the proper legal channels, ensuring their rights are protected while upholding environmental regulations. This ruling will guide future cases involving similar disputes, directing them to the appropriate courts for resolution.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.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.
Source: Heirs of Tunged vs. Sta. Lucia Realty, G.R. No. 231737, March 06, 2018