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The Supreme Court (SC) has upheld that Baguio City is exempt from ancestral claims under Republic Act No. 8371, or the Indigenous Peoples Rights Act of 1997 (IPRA), affirming its earlier decision issued on July 11, 2023.

In a recent en banc resolution, the SC denied the motion for reconsideration filed by the National Commission on Indigenous Peoples (NCIP) and the heirs of Joan Gorio and Lauro Carantes. The petitioners challenged the SC ruling that Section 78 of the IPRA explicitly exempts Baguio City from the law, maintaining that land rights in the city are instead governed by its charter.

The case originated in 1990 when the Carantes heirs sought recognition of ancestral claims to parcels of land in Baguio City, asserting their membership in the Ibaloi indigenous cultural community. Following the enactment of IPRA in 1997, jurisdiction over the claims was transferred to the NCIP, which granted the titles in 2008.

The Office of the Solicitor General (OSG) contested the NCIP’s ruling, arguing before the Court of Appeals (CA) that ancestral claims cannot apply to Baguio City due to its classification as a “townsite reservation” under its 1907 proclamation. Section 78 of the IPRA specifies that Baguio City’s lands shall remain governed by its charter and its townsite reservation status unless reclassified by law.

While the CA initially ruled in favor of the Carantes heirs, the SC overturned this in 2023, clarifying that the IPRA does not supersede earlier proclamations designating government land. However, the SC noted that indigenous peoples may still establish ownership through native title, provided they can prove continuous and actual possession of the land since time immemorial.

In the Carantes case, the SC found that the heirs failed to demonstrate uninterrupted occupation and possession of the disputed land. It emphasized that “proof of open, continuous, and actual possession up to the present” is essential for native title claims, which are pursued not under IPRA but through regular land titling processes.

Given the absence of such proof and the presence of other current occupants on the land, the SC denied the motion for reconsideration. The Court reaffirmed Baguio City’s exemption from IPRA, except for cases where native title claims can be validly established.

Supreme Court Affirms Baguio City’s Exemption from IPRA Ancestral Claims

The Supreme Court (SC) has upheld that Baguio City is exempt from ancestral claims under Republic Act No. 8371, or the Indigenous Peoples Rights Act of 1997 (IPRA), affirming its earlier decision issued on July 11, 2023.

In a recent en banc resolution, the SC denied the motion for reconsideration filed by the National Commission on Indigenous Peoples (NCIP) and the heirs of Joan Gorio and Lauro Carantes. The petitioners challenged the SC ruling that Section 78 of the IPRA explicitly exempts Baguio City from the law, maintaining that land rights in the city are instead governed by its charter.

The case originated in 1990 when the Carantes heirs sought recognition of ancestral claims to parcels of land in Baguio City, asserting their membership in the Ibaloi indigenous cultural community. Following the enactment of IPRA in 1997, jurisdiction over the claims was transferred to the NCIP, which granted the titles in 2008.

The Office of the Solicitor General (OSG) contested the NCIP’s ruling, arguing before the Court of Appeals (CA) that ancestral claims cannot apply to Baguio City due to its classification as a “townsite reservation” under its 1907 proclamation. Section 78 of the IPRA specifies that Baguio City’s lands shall remain governed by its charter and its townsite reservation status unless reclassified by law.

While the CA initially ruled in favor of the Carantes heirs, the SC overturned this in 2023, clarifying that the IPRA does not supersede earlier proclamations designating government land. However, the SC noted that indigenous peoples may still establish ownership through native title, provided they can prove continuous and actual possession of the land since time immemorial.

In the Carantes case, the SC found that the heirs failed to demonstrate uninterrupted occupation and possession of the disputed land. It emphasized that “proof of open, continuous, and actual possession up to the present” is essential for native title claims, which are pursued not under IPRA but through regular land titling processes.

Given the absence of such proof and the presence of other current occupants on the land, the SC denied the motion for reconsideration. The Court reaffirmed Baguio City’s exemption from IPRA, except for cases where native title claims can be validly established.

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