Cruz vs Secretary of DENR

Natural Resources and Environmental Law; Constitutional Law; IPRA; Regalian Doctrine
GR. No. 135385, Dec. 6, 2000

FACTS:
Petitioners filed a suit for prohibition and mandamus as citizens and taxpayers, assailing the
constitutionality of certain provisions of RA 8371, otherwise known as the Indigenous Peoples Rights
Act of 1997 (IPRA) and its implementing rules and regulations (IRR). The petitioners assail certain
provisions of the IPRA and its IRR on the ground that these amount to an unlawful deprivation of the
States ownership over lands of the public domain as well as minerals and other natural resources
therein, in violation of the regalian doctrine embodied in section 2, Article XII of the Constitution.

ISSUE:
W/N the provisions of IPRA contravene the Constitution?

HELD:
No, the provisions of IPRA do not contravene the Constitution. Examining the IPRA, there is nothing in
the law that grants to the ICCs/IPs ownership over the natural resources within their ancestral domain.
Ownership over the natural resources in the ancestral domains remains with the State and the rights
granted by the IPRA to the ICCs/IPs over the natural resources in their ancestral domains merely gives
them, as owners and occupants of the land on which the resources are found, the right to the small
scale utilization of these resources, and at the same time, a priority in their large scale development and
exploitation.

CARIO vs THE INSULAR GOVERNMENT, G.R. No. L-2746 December 6, 1906

MATEO CARIO vs THE INSULAR GOVERNMENT
G.R. No. L-2746 December 6, 1906

FACTS: Petitioner went to the Court of Land Registration to petition his inscription as the owner of a 146
hectare land hes been possessing in the then municipality of Baguio. Mateo only presented possessory
information and no other documentation. The State opposed the petition averring that the land is part
of the US military reservation. The CLR ruled in favor of Mateo. The State appealed. Mateo lost. Mateo
averred that a grant should be given to him by reason of immemorial use and occupation as in the
previous case Cansino vs Valdez & Tiglao vs Government.

ISSUE: Whether or not Mateo is the rightful owner of the land by virtue of his possession of it for some
time.

HELD: No. The statute of limitations did not run against the government. The government is still the
absolute owner of the land (regalian doctrine). Further, Mateos possession of the land has not been of
such a character as to require the presumption of a grant. No one has lived upon it for many years. It
was never used for anything but pasturage of animals, except insignificant portions thereof, and since
the insurrection against Spain it has apparently not been used by the petitioner for any purpose.
Francisco Chavez vs Public Estates Authority (July 2002)
February 27, 2012

FACTS:
The Public Estates Authority (PEA) is the central implementing agency tasked to undertake reclamation
projects nationwide. It took over the leasing and selling functions of the DENR (Department of
Environmental and Natural Resources) insofar as reclaimed or about to be reclaimed foreshore lands are
concerned.
PEA sought the transfer to the Amari Coastal Bay and Development Corporation, a private corporation,
of the ownership of 77.34 hectares of the Freedom Islands. PEA also sought to have 290.156 hectares of
submerged areas of Manila Bay to Amari.

ISSUE:
Whether or not the transfer is valid.

HELD:
No. To allow vast areas of reclaimed lands of the public domain to be transferred to Amari as private
lands will sanction a gross violation of the constitutional ban on private corporations from acquiring any
kind of alienable land of the public domain.

Republic vs Naguiat
G.R. No. 134209; January 24, 2006

FACTS:
Celestina Naguiat filed an application for registration of title to four parcels of land located in Panan,
Botolan, Zambales. The applicant alleges that she is the owner of the said parcels of land having
acquired them by purchase from its previous owners and their predecessors-in-interest who have been
in possession thereof for more than thirty (30) years; and that to the best of her knowledge, said lots
suffer no mortgage or encumbrance of whatever kind nor is there any person having any interest, legal
or equitable, or in possession thereof.

ISSUE:
Did the areas in question cease to have the status of forest or other inalienable lands of the public
domain?

HELD:
No, the said areas are still classified as forest land.The issue of whether or not respondent and her
predecessors-in-interest have been in open, exclusive and continuous possession of the parcels of land
in question is of little moment. For, unclassified land cannot be acquired by adverse occupation or
possession; occupation thereof in the concept of owner, however long, cannot ripen into private
ownership and be registered as title.