This Supreme Court decision clarifies the interplay between the Indigenous Peoples’ Rights Act (IPRA) and the Baguio City Charter concerning ancestral land claims. The Court affirmed that while IPRA generally does not apply to Baguio City, prior land rights validly acquired before IPRA’s enactment are still recognized. The case underscores that a Certificate of Ancestral Land Claim (CALC) alone does not establish valid prior land right or title, highlighting the necessity for claimants to demonstrate legally recognized rights predating IPRA’s effectivity. This ruling emphasizes the importance of adhering to established legal processes for land ownership in Baguio City, ensuring that historical claims are balanced with existing legal frameworks.

Baguio Land Dispute: Can Ancestral Claims Override City Governance?

The case of Heirs of Aida Pineda vs. Office of the President revolves around a contested land claim in Baguio City. Petitioners, the Heirs of Aida Pineda, sought to assert their rights over a parcel of land based on Certificates of Ancestral Land Claim (CALCs) issued in their favor. These certificates were granted before the enactment of the Indigenous Peoples’ Rights Act (IPRA). The respondents, the Office of the President, the Department of Environment and Natural Resources (DENR), and the Heirs of Teofilo Pilando, Sr., challenged the validity of these CALCs. They argued that Baguio City is explicitly excluded from IPRA’s coverage and that the Pilando heirs possessed prior rights to the land. The central legal question is whether the CALCs, issued before IPRA, could establish a valid claim to ancestral land in Baguio City, despite the city’s exclusion from the Act.

The roots of the dispute trace back to 1991 when Aida Pineda applied for an ancestral land claim over approximately 49,645 square meters in Baguio City. This application was made under DENR Special Order No. 31, series of 1990, which aimed to process ancestral land claims in the Cordillera Administrative Region. Subsequently, in 1993, the DENR issued four CALCs in favor of Pineda, covering 61,673 square meters. However, in 1996, the Heirs of Teofilo Pilando, Sr. filed a Petition for Annulment of the CALCs, asserting a prior right based on their predecessor’s long-term occupation and improvements on the land. This claim originated from Teofilo Pilando, Sr.’s purchase of the land in the 1950s, his subsequent survey, and tax declarations.

The DENR, in its 2007 decision, ordered the recall of the CALCs issued to Pineda, emphasizing that the Special Task Force’s recommendations were not binding, especially considering Baguio City’s exclusion from IPRA. The Office of the President affirmed this decision in 2011, stating that the CALCs lacked legal basis, both before and after IPRA’s enactment. This decision underscored that the Pilando heirs had acquired a right to government grant due to their continuous possession and occupation of the land. The Court of Appeals upheld these rulings, reinforcing the provisional nature of the CALCs and the DENR’s administrative jurisdiction over the matter. Thus, the Heirs of Pineda elevated the case to the Supreme Court, arguing that Baguio City’s exemption from IPRA should not negate their native title over the ancestral land.

The Supreme Court anchored its decision on Section 78 of IPRA, which explicitly excludes Baguio City from the Act’s application. This provision mandates that Baguio City remains governed by its Charter, and lands proclaimed as part of its townsite reservation retain that status until reclassified by appropriate legislation. The Court, citing Republic v. National Commission on Indigenous Peoples, emphasized that Section 78 provides specific guidelines for land rights within Baguio City. These include recognizing prior land rights and titles acquired through judicial, administrative, or other processes before IPRA’s effectivity, and exempting territories that became part of Baguio City after IPRA’s enactment. This framework clearly delineates that IPRA does not generally authorize the NCIP to issue ancestral land titles within Baguio City, except under specific conditions.

Building on this principle, the Court addressed the validity of the Certificates of Ancestral Land Claim held by the petitioners. Citing Philippine Economic Zone Authority v. Borreta, the Court reiterated that a CALC does not confer vested ownership rights. It merely acknowledges the claimant’s right to occupy and cultivate the land, subject to existing laws and regulations. Moreover, the Court referenced Philippines Economic Zone Authority v. Carantes, outlining the limited rights of CALC holders, primarily focusing on occupation for cultivation rather than the right to build permanent structures or exercise full ownership. These precedents establish that a CALC, by itself, does not equate to a recognized title or right that supersedes existing legal frameworks governing land ownership.

This approach contrasts with the petitioners’ argument that their CALCs establish prior land rights protected under Section 78 of IPRA. The Court clarified that the Special Task Force, which issued the CALCs, was organized to prepare for the anticipated enactment of IPRA. The certificates were intended to be provisional, pending the passage of enabling legislation. The petitioners were still required to convert these CALCs to Certificates of Ancestral Land Title (CALTs) under the guidelines of NCIP Administrative Order No. 2-02. However, they failed to complete this conversion, thus weakening their claim to a legally recognized title. The decision underscores the necessity for claimants to demonstrate a clear legal basis for their land rights that predates IPRA’s enactment.

The Court further addressed the petitioners’ claim of native title, a concept rooted in the long-term occupation and use of land since time immemorial. While acknowledging the principle established in Cariño v. Insular Government, which recognized the validity of native title, the Court emphasized the need for concrete evidence to support such claims. The case of Republic v. National Commission on Indigenous Peoples elucidated the governing law for prior land rights in Baguio City, referencing Act No. 926 and Act No. 627, which mandated the registration of land titles within a specified period. Failure to comply with these registration requirements resulted in the barring of land rights. In this context, the Court found that the petitioners failed to provide sufficient evidence that their rights over the properties were validly recognized in any administrative or judicial proceedings before IPRA’s effectivity.

Ultimately, the Supreme Court underscored that it is not a trier of facts and will generally defer to the factual findings of lower courts, especially when supported by substantial evidence. The petitioners’ invitation to the Court to re-evaluate the evidence was declined, as they failed to demonstrate a clear case warranting a factual review. The Court emphasized that the burden of proving prior and preeminent right over the land rests on the petitioners, a burden they failed to discharge. Thus, the Court affirmed the decisions of the Court of Appeals, the Office of the President, and the DENR, effectively denying the Heirs of Aida Pineda’s claim to ancestral land in Baguio City.

FAQs

What was the central issue in this case?	The central issue was whether the Certificates of Ancestral Land Claim (CALCs) issued to the Heirs of Aida Pineda constituted a valid claim to ancestral land in Baguio City, considering the city’s exclusion from the Indigenous Peoples’ Rights Act (IPRA).
Why is Baguio City excluded from IPRA?	Section 78 of IPRA specifically excludes Baguio City from the application of its provisions, stating that the city remains governed by its own Charter and that lands proclaimed as part of its townsite reservation retain that status.
What is a Certificate of Ancestral Land Claim (CALC)?	A CALC is a document issued by the DENR recognizing a claim to ancestral land. However, it does not confer ownership rights but acknowledges the claimant’s right to occupy and cultivate the land, subject to existing laws and regulations.
What is required to establish a valid ancestral land claim in Baguio City?	To establish a valid ancestral land claim, claimants must demonstrate prior land rights and titles recognized or acquired through judicial, administrative, or other processes before IPRA’s effectivity.
What was the basis of the Pilando heirs’ claim?	The Pilando heirs based their claim on their predecessor’s long-term occupation and improvements on the land, originating from Teofilo Pilando, Sr.’s purchase of the land in the 1950s, subsequent survey, and tax declarations.
Why did the Supreme Court deny the Pineda heirs’ petition?	The Supreme Court denied the petition because the Pineda heirs failed to establish valid prior land rights recognized before IPRA’s enactment and because a CALC alone does not confer ownership rights.
What is the significance of the Cariño v. Insular Government case?	The Cariño case established the principle of recognizing native title, based on long-term occupation and use of land since time immemorial, which the petitioners attempted to invoke in their claim.
What is the implication of Act No. 926 and Act No. 627 in this case?	Act Nos. 926 and 627 mandated the registration of land titles within a specified period, and failure to comply with these registration requirements resulted in the barring of land rights, which affected the petitioners’ claim.
Did the Supreme Court make a new decision regarding ownership of the land?	No, the Supreme Court did not make a new decision regarding ownership but affirmed previous rulings which stated Petitioners failed to provide evidence of their land claim in the present case. Thus, they may prove if their claim is meritorious in a separate proceeding.

This case underscores the complexities of land ownership disputes in Baguio City, particularly those involving ancestral land claims. The Supreme Court’s decision highlights the importance of adhering to established legal processes and demonstrating legally recognized rights predating the enactment of the Indigenous Peoples’ Rights Act. Moving forward, individuals and communities seeking to assert ancestral land rights in Baguio City must present comprehensive evidence of prior valid titles or rights, ensuring compliance with relevant laws and regulations.

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 AIDA PINEDA VS. OFFICE OF THE PRESIDENT, G.R. No. 223808, April 26, 2023