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G.R. No. 135385. December 06, 2000 (Case Brief - Digest)

The Supreme Court case G.R. No. 135385 involved petitioners challenging the constitutionality of certain provisions of the Indigenous Peoples’ Rights Act (IPRA) regarding ownership of natural resources and ancestral domains. The Court upheld the IPRA, stating it recognizes indigenous peoples' rights to ancestral lands, which are not considered public domain, and found no infringement on private property rights. The decision emphasizes the legal protection of indigenous peoples' rights to their ancestral domains, reflecting the government's efforts to address historical injustices.

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6 views2 pages

G.R. No. 135385. December 06, 2000 (Case Brief - Digest)

The Supreme Court case G.R. No. 135385 involved petitioners challenging the constitutionality of certain provisions of the Indigenous Peoples’ Rights Act (IPRA) regarding ownership of natural resources and ancestral domains. The Court upheld the IPRA, stating it recognizes indigenous peoples' rights to ancestral lands, which are not considered public domain, and found no infringement on private property rights. The decision emphasizes the legal protection of indigenous peoples' rights to their ancestral domains, reflecting the government's efforts to address historical injustices.

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Jewel Heart Avenilla
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No. 135385.

December 06, 2000 (Case Brief / Digest)

Title: Isagani Cruz and Cesar Europa vs. Secretary of Environment and Natural
Resources, et al. (G.R. No. 135385 October 12, 2000)

Facts: The case arose when petitioners Isagani Cruz and Cesar Europa, as citizens and
taxpayers, filed a suit for prohibition and mandamus questioning the constitutionality of
certain provisions of the Indigenous Peoples’ Rights Act of 1997 (IPRA), or Republic Act No.
8371, and its Implementing Rules and Regulations (IRR). They argued that these provisions
unlawfully deprived the State of its ownership over lands of the public domain and the
natural resources therein, in violation of the Regalian Doctrine embodied in Section 2,
Article XII of the 1987 Constitution. They also contended that the law’s definition of
“ancestral domains” and “ancestral lands,” which could include private lands, violated the
rights of private landowners.

After the filing of the petition, respondents required by the Supreme Court filed their
respective comments. The National Commission on Indigenous Peoples (NCIP) defended the
constitutionality of the IPRA. The Secretary of the Department of Environment and Natural
Resources (DENR) and the Secretary of Budget and Management, through the Solicitor
General, partially agreed with the petitioners regarding the unconstitutionality of the
provisions granting ownership of natural resources to indigenous peoples. Several groups of
intervenors, comprising indigenous peoples and their supporting organizations, along with
the Commission on Human Rights and other related entities, filed motions to intervene,
supporting the constitutionality of the IPRA.

The Supreme Court deliberated on the case, and votes were equally divided; therefore,
pursuant to Rule 56, Section 7 of the Rules of Civil Procedure, the petition was dismissed,
upholding the validity of the challenged provisions of R.A. 8371.

Issues: The core legal issues revolved around:


1. Whether the provision of IPRA granting ownership over natural resources to indigenous
peoples is unconstitutional for being contrary to the Regalian Doctrine.
2. Whether the provisions related to the identification, delineation, and recognition of
ancestral domains infringe upon the due process clause of the Constitution.
3. Whether certain aspects of IPRA violate the rights of private landowners.
4. Whether the administrative relationship of the NCIP to the Office of the President, as
characterized in the NCIP Administrative Order No. 1, contradicts the President’s control
over executive departments.

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G.R. No. 135385. December 06, 2000 (Case Brief / Digest)

Court’s Decision:
The Supreme Court dismissed the petition, maintaining the constitutionality of the
challenged provisions. The Court explained that the IPRA did not violate the Regalian
Doctrine, as it merely recognized the indigenous peoples’ right to their ancestral domains
and lands, a right considered never to have been part of the public domain. Moreover, the
IPRA provided safeguards to ensure that the delineation and recognition of ancestral
domains would not infringe upon private property rights. The Court also found no merit in
the argument regarding the NCIP’s administrative relationship with the Office of the
President, stating that it did not diminish the President’s control over the executive
department.

Doctrine: The case reiterates the doctrine that the rights of indigenous peoples over their
ancestral domains are recognized and protected under the law. It emphasized that ancestral
domains and lands, occupied, possessed, and utilized by indigenous peoples and their
ancestors since time immemorial, are presumed never to have been public lands and are
considered private.

Class Notes:
1. Regalian Doctrine (Section 2, Article XII, 1987 Constitution) – All lands of the public
domain and natural resources belong to the State.
2. Indigenous Peoples’ Rights Act of 1997 (IPRA, R.A. 8371) – Recognizes and promotes the
rights of Indigenous Cultural Communities/Indigenous Peoples (ICCs/IPs) to their ancestral
domains and lands.
3. Ancestral Domains and Ancestral Lands – Defined under IPRA as areas occupied and
possessed by Indigenous Peoples under claims of individual or collective ownership since
time immemorial.
4. Native Title – Acknowledges the pre-conquest rights of indigenous peoples to lands and
domains held under claims of ownership since time immemorial.
5. The principle of due process and equal protection of the laws (Section 1, Article III, 1987
Constitution) – No person shall be deprived of life, liberty, or property without due process
of law, nor shall any person be denied the equal protection of the laws.

Historical Background: This case underscores the Philippine government’s recognition and
protection of the rights of indigenous peoples to their ancestral lands and domains. It
reflects the state’s efforts to correct historical injustices suffered by indigenous
communities by formalizing their claims to territories they have traditionally owned and
utilized.

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