Cruz v. Sec. of Environment And Natural Resources, G.R. No.

135385, December 6, 2000

FACTS:

Petitioners Isagani Cruz and Cesar Europa brought a suit of prohibition and mandamus as citizens and
taxpayers assailing the constitutionality of certain provisions of R.A 8371 also known as Indigenous
Peoples Rights Act (IPRA), and its Implementing Rules and Regulations (IRR). Several groups such as
Haribon ET. Al, and CHR filed motion to intervene which was granted by the court.

Petitioners aver that provisions of RA 83171 in sections of IPRA particularly the sections 3(a) and 3(b),
section 6, 7 and 8 and sections 57 and 58, being contrary to the regalia Doctrine. They also assailed the
provisions of RA 8371 defining the powers and jurisdiction of the NCIP on the ground that the provisions
violate the due process clause of the Constitution.

ISSUE:

Whether or not the assailed sections of the IPRA law are unconstitutional.

HELD:

The Court was divided equally, where 7 members voted for the dismissal and the other 7 voting for the
grant of petition. As majority was not obtained, the case was redeliberated upon, However after such
redeliberation, the voting remained, pursuant to the Rules of Court, the petition was dismissed. Thus
we look upon the separate opinions made by Justices Puno, Vitug, Kapunan, Mendoza and Panganiban
to look upon how the issue was addressed in their opinions.
Loloy Unduran v. Ramon Aberasturi, G.R. No. 181284, October 20, 2015

FACTS:

Petitioners are members of the Miarayon, Lapok, Lirongan, Talaandig Tribal Association (MILALITTRA), or
Talaandig tribe, who claimed to have been living since birth on the land located at Barangay Miarayon,
Talakag, Bukidnon, Mindanao, which they inherited from their forefathers.

Respondents, represented by attorney-in-fact Ramon Aberasturi, claimed to be the lawful owners and
possessor of an unregistered parcel of agricultural land.

On March 3, 2004, respondents filed a Petition for Accion Reivindicatoria, with Prayer for the Issuance of
a Temporary Restraining Order or Preliminary Prohibitory Injunction with Damages before the Regional
Trial Court of Manolo Fortich, Bukidnon (RTC).

On March 23, 2004, the rest of the petitioners filed their Motion to Dismiss, alleging that the RTC had no
jurisdiction over the case.

As awardees of a CADT, petitioners argued that NCIP has exclusive and original jurisdiction over the
case, as the subject matter concerns a dispute and controversy over an ancestral land/domain of
Indigenous Cultural Communities (ICCs)/Indigenous Peoples (IPs).

On July 1, 2004, the NCIP through Atty. Melanie Pimentel, filed a Motion to Refer the Case to the
Regional Hearing Office-National Commission on Indigenous Peoples (RHO-NCIP), alleging that the RTC
had no jurisdiction over the subject matter.

ISSUE: In resolving the pivotal issue of which between the RTC and the NCIP has jurisdiction over the
respondents' amended complaint.

HELD: The petition has no merit.

Court disagrees with their contention that petitioners do not have legal capacity or standing and locus
standi to file the petition, for failure to show that they are members of IPs/ICCs, or that they are
authorized to represent the Talaandig tribe.

That petitioners are the real parties in interest can be gleaned from the Entry of Appearance with
Motion to Refer the Case to the Regional Hearing Office of the NCIP filed by the NCIP Special Transition
Team-Quick Response Unit (STRAT-QRU). The STRAT-QRU counsels alleged therein that the respondents'
complaint for recovery of ownership (accion reinvidicatoria) sought to recover an unregistered real
property situated in Miarayon, Bukidnon, from petitioners, all of whom are, with the exception of
Nestor Macapayag and Mark Brazil, member-beneficiaries of CADT No. R10-TAL-0703-0010 issued by
the NCIP in the name of the Talaandig Indigenous Peoples, located at Talakag, Province of Bukidnon. In
support of their allegation, petitioners presented a certification that the disputed land is within the area
covered by the same CADT, and the NCIP List of Beneficiaries of Talaandig Ancestral Domain of
Miarayon, Lirongan, Lapok, San Miguel, Talakag, Bukidnon.
In contrast, respondents failed to submit any evidence to dispute petitioners' claim that they are
members of the Talaandig Tribe. Hence, respondents' contention that petitioners have no legal standing
to file the petition, is without merit.

Having spelled out the jurisdictions conferred by law to the RTC and the NCIP over the subject matters
of their respective cases, the Court now examines the allegations in the original and amended
complaints to find out which tribunal may properly exercise jurisdiction over this case.

Respondents traced the provenance of their title over said land to one Mamerto Decano, a Chieftain of
Talaandig tribe, by virtue of a Deed of Sale executed on July 27, 1957.

They claimed that by means of fraud, stealth and surreptitious means, petitioners entered the said land,
without permission and against the consent of the landowners, caused damages therein and harassed
respondents by indiscriminately firing upon their farm workers.

The Court therefore finds that the CA correctly ruled that the subject matter of the amended complaint
based on allegations therein was within the jurisdiction of the RTC.

Contrary to petitioners' contention, the mere fact that this case involves members of ICCs/IPs and their
ancestral land is not enough to for it to fall under the jurisdiction of the NCIP under Section 66 of the
IPRA, to wit:

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.

The qualifying provision requires two conditions before such disputes may be brought before the NCIP,
namely: (1) exhaustion of remedies under customary laws of the parties, and (2) compliance with
condition precedent through the said certification by the Council of Elders/Leaders.

In this case, while most of the petitioners belong to Talaandig Tribe, respondents do not belong to the
same ICC/IP.

Thus, even if the real issue involves a dispute over lands which appear to be located within the ancestral
domain of the Talaandig Tribe, it is not the NCIP but the RTC which shall have the power to hear, try and
decide this case. The Court declares Rule IX, Section 1 of the IPRA-IRR, Rule III, Section 5 and Rule IV,
Sections 13 and 14 of the NCIP Rules as null and void insofar as they expand the jurisdiction of the NCIP
under Section 66 of the IPRA to include such disputes where the parties do not belong to the same
ICC/IP.

WHEREFORE, the petition is DENIED.

Engineer Ben Y. Lim, et al. v. Hon. Sulpicio G. Gamosa, G.R. No. 193964, December 2, 2015

FACTS:

Respondent Tagbanua Indigenous Cultural Community of Barangay Buenavista, Coron, Palawan filed a
petition before the National Commission on Indigenous People (NCIP) against petitioners for Violation
of Rights to Free and Prior and Informed Consent (FPIC) and Unauthorized and Unlawful Intrusion with
Prayer for the Issuance of Preliminary Injunction and TRO.

Despite a motion to dismiss being a prohibited pleading under NCIP Administrative Circular No. 1-03,
petitioners moved to dismiss the petition on the ground, among others, that NCIP lack jurisdiction over
the subject matter of the petition because petitioners are not members of the ICC/IP. The NCIP,
however, resolved to deny the motion to dismiss. Likewise, the Court of Appeals affirmed the NCIPs
denial and reasoned out that from the wording of Section 66 of the IPRA, the NCIP was bestowed with
an all-encompassing grant of jurisdiction over all claims and disputes involving rights of ICCs/IPs and that
the requirement in the proviso contained in the section i.e. obtaining certification from the Council of
Elders/Leaders that the parties had exhausted all remedies provided under their customary law prior to
the filing of an action, applied only to instances where both parties were members of an ICC/IP. In all,
the Court of Appeals upheld that when a claim or dispute involves rights of the ICCs/IPs, the NCIP has
jurisdiction over the case regardless of whether the opposing party is a non-ICC/IP.

Petitioners thus filed this petition for review on certiorari.

ISSUE:

Does the NCIP have jurisdiction over the subject matter of the instant case?

HELD:

NO. SECTION 66 of the IPRA is exclusionary, specifically excluding disputes involving rights of ICCs/IPs
where opposing party is a non-ICC/IP. This provision reflects IPRAs emphasis of customs and customary
law to govern in the lives of the ICCs/IPs. In fact, even the IPRA itself recognizes that customs and
customary law cannot be applied to non-ICCs/IPs since ICCs/IPs are recognized as a distinct sector of the
Philippine society.

The limited or special jurisdiction of the NCIP, confined only to a special cause involving ICCs/IPs, can
only be exercised under the limitations and circumstances prescribed by the statute.

Former Chief Justice Reynato Puno, in his separate opinion in Cruz v. Secretary of Environment and
Natural Resources, emphasizes the primacy of customs and customary law in the lives of the members
of the ICCs/IPs:
Custom, from which customary law is derived, is also recognized under the Civil Code as a source of law
x x x. [I]n the absence of any applicable provisions in the Civil Code, custom, when duly proven, can
define rights and liabilities.

Customary law is a primary, not secondary, source of rights under the IPRA and uniquely applies to
ICCs/IPs. Its recognition does not depend on the absence of a specific provision in the civil law. The
indigenous concept of ownership under customary law is specifically acknowledged and recognized, and
coexists with the civil law concept and the laws on land titling and land registration.

Once again, the primacy of customs and customary law sets the parameters for the NCIPs limited
and special jurisdiction and its consequent application in dispute resolution. Demonstrably, the proviso
in Section 66 of the IPRA limits the jurisdiction of the NCIP to cases of claims and disputes involving
rights of ICCs/IPs where both parties are ICCs/IPs because customs and customary law cannot be made
to apply to non-ICCs/IPs within the parameters of the NCIPs limited and special jurisdiction.

Clearly, the phraseology of all claims and disputes involving rights of ICCs/IPs does not necessarily
grant the NCIP all-encompassing jurisdiction whenever the case involves rights of ICCs/IPs without
regard to the status of the parties, i.e, whether the opposing parties are both ICCs/IPs.

WHEREFORE, the appeal is granted. The NCIPs Resolution is reversed and set aside and respondents
may refile their complaint against petitioners in a court of general jurisdiction.
Tanenglain v. Lorenzo, et al., G.R. No. 173415, March 28, 2008

FACTS:

This case involves two parcels of land (subject properties), located and adjacent to the Sto. Tomas
Baguio Road, with areas of 7,860 square meters and 21,882 square meters, covered respectively by
Transfer Certificates of Title (TCT) No. T-29281 and T-29282 registered in the Registry of Deeds of Baguio
City both in the name of petitioner.

Respondents Silvestre Lorenzo, et al., members of the Indigenous Cultural Minority of the Cordillera
Administrative Region, filed a Petition for Redemption under Sec. 12, Republic Act No. 3844 dated 29
July 1998 before the Department of Agrarian Reform Adjudication Board (DARAB) praying that: (1) they
be allowed to exercise their right of redemption over the subject properties; (2) TCTs No. T-29281and T-
29282 in the name of petitioner be declared null and void; (3) the subject properties be declared as
ancestral land pursuant to Section 9 of Republic Act No. 6657; and (4) petitioner be ordered to pay
disturbance compensation to respondents.

Adjudicator ruled in favor of Lorenzo and ruled that the lands are ancestral lands and the TCTs are null
and void because the titles of Tanenglians predecessors in interest were secured by fraud. The decision
was affirmed by DARAB and then the CA thus Tanenglians appeal to the SC. He argues that the DARAB
does not have jurisdiction over the controversy and furthermore, that the declaration of the land as
ancestral land was done with grave abuse of discretion amounting to lack or excess of jurisdiction.

ISSUE:

Whether or not Tanenglian was wrongfully deprived of his land.

HELD:

Yes. Ra 8371, or the IPRA specifically provides a more thorough definition of ancestral lands and it
designates the NCIP (Natl Commission on Indigenous Peoples) as the primary govt agency responsible.
The DARAB was w/o jurisdiction when it declared that the properties are ancestral land. More
importantly, the regional adjudicator was w/o jurisdiction in entertaining a collateral attack on
Tanenglians TCTs. In an earlier case for quieting of title, Tanenglians title to the properties was already
affirmed with finality. A suit for quieting of title is an action quasi in rem: conclusive to the parties to the
suit. Nevertheless, Lorenzo cannot pray for the Regional Adjudicator to declare the TCTs null and void
for it would constitute a collateral attack on his titles which is NOT allowed.

Doctrine: A collateral attack is made when in another action to obtain a different relief, an attack on the
judgment is made as an INCIDENT to said action. This is compared to a direct attack, whose main object
is to annul a judgment. In this case, Tanenglians titles have acquired the character of indefeasibility so it
CANNOT be collaterally questioned.

WHEREFORE, premises considered, the instant petition is GRANTED.

Lamsis, Et. Al. V. Dong-Eg.R. No. 173021, October 20, 2010

FACTS:

This case involves a conflict of ownership and possession over an untitled parcel of land located along
Km. 5 Asin Road, Baguio City. While petitioners are the actual occupants of Lot No. 1, respondent is
claiming ownership thereof and is seeking to recover its possession from petitioners. According to
respondent Margarita Semon Dong-E (Margarita), her familys ownership and occupation of Lot No. 1
can be traced as far back as 1922 to her late grandfather, Ap-ap. Upon Ap-aps death, the property was
inherited by his children, who obtained a survey plan in 1964 of the 186,090-square meter property,
which included Lot No. 1.
The heirs of Ap-ap then executed, for a P500.00 consideration, a Deed of Quitclaim on February 26,
1964 in favor of their brother Gilbert Semon (Margaritas father). Sometime between 1976 and 1978,
Gilbert Semon together with his wife Mary Lamsis, allowed his in-laws Manolo Lamsis and Nancy Lamsis-
Kitma, to stay on a portion of Lot No. 1 together with their respective families. When Gilbert Semon died
in 1983, his children extrajudicially partitioned the property among themselves and allotted Lot No. 1
thereof in favor of Margarita.The state of affairs changed when petitioners Delfin and Agustin allegedly
began expanding their occupation on the subject property and selling portions thereof.[16] Delfin
allegedly sold a 400-square meter portion of Lot No. 1 to petitioner Maynard Mondiguing (Maynard)
while Agustin sold another portion to petitioner Jose Valdez (Jose).

Margarita filed a complaint for recovery of ownership, possession, reconveyance and damages against
all four occupants of Lot No. 1 before the Regional Trial Court (RTC) of Baguio City. To bolster her claim
of ownership and possession, Margarita introduced as evidence an unnumbered resolution of the
Community Special Task Force on Ancestral Lands (CSTFAL) of the Department of Environment and
Natural Resources (DENR), acting favorably on her and her siblings ancestral land claim over a portion of
the 186,090-square meter property.

ISSUES:

1. Whether the ancestral land claim pending before the National Commission on Indigenous
Peoples (NCIP) should take precedence over the reivindicatory action.

2. Whether the trial court has jurisdiction to decide the case in light of the effectivity of RA 8371 or
the Indigenous Peoples Rights Act of 1997 at the time that the complaint was instituted.

HELD:

1. The Court held that a registration proceeding (such as the certification of ancestral lands) is not a
conclusive adjudication of ownership, hence, it will not constitute litis pendentia on a reivindicatory case
where the issue is ownership. For litis pendentia to be a ground for the dismissal of an action, the
following requisites must concur: (a) identity of parties, or at least such parties who represent the same
interests in both actions; (b) identity of rights asserted and relief prayed for, the relief being founded on
the same facts; and (c) the identity with respect to the two preceding particulars in the two cases is such
that any judgment that may be rendered in the pending case, regardless of which party is successful,
would amount to res judicata in the other case.The third element is missing, for any judgment in the
certification case would not constitute res judicata or be conclusive on the ownership issue involved in
the reivindicatory case. Since there is no litis pendentia, there is no reason for the reivindicatory case to
be suspended or dismissed in favor of the certification case.
Moreover, since there is no litis pendentia, we cannot agree with petitioners contention that
respondent committed forum-shopping. Settled is the rule that forum shopping exists where the
elements of litis pendentia are present or where a final judgment in one case will amount to res judicata
in the other.

2. As a rule, an objection over subject-matter jurisdiction may be raised at any time of the proceedings.
An exception to this rule has been carved by jurisprudence. the Court ruled that the existence of laches
will prevent a party from raising the courts lack of jurisdiction. Laches is defined as the failure or neglect,
for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could
or should have been done earlier; it is negligence or omission to assert a right within a reasonable time,
warranting the presumption that the party entitled to assert it either has abandoned or declined to
assert it. At the time that the complaint was first filed in 1998, the IPRA was already in effect but the
petitioners never raised the same as a ground for dismissal; instead they filed a motion to dismiss on the
ground that the value of the property did not meet the jurisdictional value for the RTC. They obviously
neglected to take the IPRA into consideration.

Thus, even assuming arguendo that petitioners theory about the effect of IPRA is correct (a matter
which need not be decided here), they are already barred by laches from raising their jurisdictional
objection under the circumstances.
Central Mindanao University v. The Honorable Executive Secretary, Et. Al., G.R. No. 184869,
September 21, 2010

FACTS:

Petitioner Central Mindanao University (CMU) is a chartered educational institution owned and run by
the State. In 1958, the President issued Presidential Proclamation 476, reserving 3,401 hectares of lands
of the public domain in Musuan, Bukidnon, as school site for CMU. Eventually, CMU obtained title in its
name over 3,080 hectares of those lands under Original Certificates of Title (OCTs) 0-160, 0-161, and 0-
162. Meanwhile, the government distributed more than 300 hectares of the remaining untitled lands to
several tribes belonging to the areas cultural communities.

Forty-five years later, President Gloria Macapagal-Arroyo issued Presidential Proclamation 310 that
takes 670 hectares from CMUs registered lands for distribution to indigenous peoples and cultural
communities in Barangay Musuan, Maramag, Bukidnon. On April 3, 2003, however, CMU filed a petition
for prohibition against respondents Executive Secretary, Secretary of the Department of Environment
and Natural Resources, Chairperson and Commissioner of the National Commission on Indigenous
Peoples (NCIP), and Lead Convenor of the National Anti-Poverty Commission (collectively, NCIP, et al)
before the Regional Trial Court (RTC) of Malaybalay City (Branch 9), seeking to stop the implementation
of Presidential Proclamation 310 and have it declared unconstitutional.

The NCIP, et al moved to dismiss the case on the ground of lack of jurisdiction of the Malaybalay RTC
over the action, pointing out that since the act sought to be enjoined relates to an official act of the
Executive Department done in Manila, jurisdiction lies with the Manila RTC. The Malaybalay RTC denied
the motion, however, and proceeded to hear CMUs application for preliminary injunction. Meanwhile,
respondents NCIP, et al moved for partial reconsideration of the RTCs order denying their motion to
dismiss.

On October 27, 2003, after hearing the preliminary injunction incident, the RTC issued a resolution
granting NCIP, et als motion for partial reconsideration and dismissed CMUs action for lack of
jurisdiction. Still, the RTC ruled that Presidential Proclamation 310 was constitutional, being a valid State
act. The RTC said that the ultimate owner of the lands is the State and that CMU merely held the same
in its behalf. CMU filed a motion for reconsideration of the resolution but the RTC denied the same on
April 19, 2004. This prompted CMU to appeal the RTCs dismissal order to the Court of Appeals (CA)
Mindanao Station. However, the CA dismissed the case ruling that CMUs recourse should have been a
petition for review on certiorari filed directly with this Court, because it raised pure questions law
bearing mainly on the constitutionality of Presidential Proclamation 310. The CA added that whether the
trial court can decide the merits of the case based solely on the hearings of the motion to dismiss and
the application for injunction is also a pure question of law.

ISSUE:

Whether or not PD 310 can validly distribute lands already owned by CMU to the ICCs/IPs in Musuan,
Marang, Bukidnon
HELD:

No, these state colleges and universities are the main vehicles for our scientific and technological
advancement in the field of agriculture, so vital to the existence, growth and development of this
country. It did not matter that it was President Arroyo who, in this case, attempted by proclamation to
appropriate the lands for distribution to indigenous peoples and cultural communities. As already
stated, the lands by their character have become inalienable from the moment President Garcia
dedicated them for CMUs use in scientific and technological research in the field of agriculture. They
have ceased to be alienable public lands.

Besides, when Congress enacted the Indigenous Peoples Rights Act (IPRA) or Republic Act 8371 in 1997,
it provided in Section 56 that "property rights within the ancestral domains already existing and/or
vested" upon its effectivity "shall be recognized and respected." In this case, ownership over the subject
lands had been vested in CMU as early as 1958. Consequently, transferring the lands in 2003 to the
indigenous peoples around the area is not in accord with the IPRA.
Thomas Begnaen V. Spouses Caligtan, G.R. No. 189852, August 17, 2016

FACTS:

On 3 August 2006, petitioner Thomas Begnaen (Begnaen) filed a Complaint with Prayer for Preliminary
Injunction against respondents Spouses Leo and Elma Caligtan (Sps. Caligtan) for "Land Dispute and
Enforcement of Rights" before the Regional Hearing Office (RHO) of the NCIP at La Trinidad, Benguet.
The RHO thereafter issued an Order dismissing the complaint based on respondents' argument that the
case should have gone to the council of elders and not through the Barangay Lupon, as mandated by the
Indigenous Peoples' Rights Act (IPRA).

However, instead of abiding by the Order of the RHO, Begnaen filed against the Sps. Caligtan a
Complaint for Forcible Entry with a Prayer for a Writ of Preliminary Mandatory Injunction before the
Municipal Circuit Trial Court (MCTC) of Bauko-Sabangan, Mt. Province.

Begnaen alleged that he was the owner of a 125 square meter parcel of land situated in Supang,
Sabangan, Mt. Province. He claimed that on two occasions, respondents - by using force, intimidation,
stealth, and threat -entered a portion of the subject property, hurriedly put up a chicken-wire fence, and
started building a shack thereon without Begnaen's knowledge and consent.

Meanwhile, respondents averred that they owned the area in question as part of the land they had
purchased from a certain Leona Vicente in 1959 pursuant to age-old customs and traditions. They
introduced improvements evidencing their prior physical possession. Respondents further contended
that when petitioner's father Alfonso Begnaen (Alfonso) was still alive, he had always respected their
boundary wherein a "GIKAD" or old pine tree lumber was buried and recovered. The "GIKAD"
established their boundary pursuant to age-old Igorot customs and traditions. To further mark their
boundary, respondents also planted bushes and a mango tree, all of which Alfonso had likewise
respected.

MCTC dismissed the ejectment complaint in favor of respondents. However, this was without prejudice
to the filing of a case before the RHO of the NCIP, which the MCTC recognized had primary, original, and
exclusive jurisdiction over the matter pursuant to the IPRA. The MCTC further reasoned that the fact
that petitioner initially filed a complaint with the NCIP-RHO shows that he recognized the primary
jurisdiction of the NCIP. Aggrieved, petitioner-appellant filed an appeal before Regional Trial Court
Branch 35 of Bontoc, Mt. Province (RTC).

RTC reversed and set aside the Resolution and Order of the MCTC, saying that it was the latter court that
had jurisdiction over the case for forcible entry. The RTC reasoned that the provisions of the IPRA
pertaining to jurisdiction do not espouse exclusivity and thus cannot divest the MCTC of its jurisdiction
over forcible entry and unlawful detainer cases as provided by B.P. Blg. 129. According to the RTC, IPRA
must be read to harmonize with B.P. Blg. 129. Respondent-appellees then moved for a reconsideration
of the above Decision, but their motion was denied by the RTC . Undaunted, respondents appealed to
the CA.

CA reversed and set aside the RTC rulings and reinstated the Resolution of the MCTC. In upholding the
jurisdiction of the NCIP over the present case, the CA ruled that the passage of the IPRA has divested
regular courts of their jurisdiction when the parties involved are members of ICCs/IPs and the disputed
property forms part of their ancestral land/domain. Petitioner filed a Motion for Reconsideration, but it
was denied by the CA in its questioned Resolution.

ISSUE:

Whether or not the National Commission on Indigenous Peoples (NCIP) have jurisdiction over the
subject ancestral land dispute between members of an Indigenous Cultural Community (ICC) to the
exclusion of regular courts.

HELD:

The NCIP Rule purporting to establish the jurisdiction of the NCIP-Regional Hearing Officer as original
and exclusive has been declared VOID for expanding the law.

The Court ruled that the NCIP cannot be said to have even primary jurisdiction over all the ICC/IP cases.
There is no specificity in the grant of jurisdiction to the NCIP in Section 66 of the IPRA. Neither does the
IPRA confer original and exclusive jurisdiction to the NCIP over all claims and disputes involving rights of
ICCs/IPs.

The implementing rules and regulations of a law cannot extend the law or expand its coverage, as the
power to amend or repeal a statute is vested in the legislature. Indeed, administrative issuances must
not override, but must remain consistent with the law they seek to apply and implement. They are
intended to carry out, not to supplant or to modify, the law.

Perforce, in this case, the NCIPs Administrative Circulars1 classification of its RHOs jurisdiction as
original and exclusive, supplants the general jurisdiction granted by Batas Pambansa Bilang 129 to the
trial courts and ultimately, modifies and broadens the scope of the jurisdiction conferred by the IPRA on
the NCIP. We cannot sustain such a classification.

At best, the limited jurisdiction of the NCIP is concurrent with that of the regular trial courts in the
exercise of the latters general jurisdiction extending to all controversies brought before them within the
legal bounds of rights and remedies.

WHEREFORE, the instant Petition for Review is DENIED.