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ISAGANI CRUZ v. SECRETARY OF ENVIRONMENT

FACTS:

The petitioners, Isagani Cruz and Cesar Europa, brought a suit challenging the constitutionality of Republic Act No. 8371 (IPRA) and its implementing rules and regulations. They argued that certain provisions of the IPRA violated the regalian doctrine and deprived the state of ownership of public lands, minerals, and natural resources. The respondents in the case were the Chairperson and Commissioners of the National Commission on Indigenous Peoples (NCIP), the Secretary of the Department of Environment and Natural Resources (DENR), and the Secretary of the Department of Budget and Management (DBM). The Solicitor General, representing the government, expressed that the IPRA was partly unconstitutional. Several intervenors, including Sen. Juan Flavier, Mr. Ponciano Bennagen, 112 groups of indigenous peoples, the Commission on Human Rights (CHR), the Ikalahan Indigenous People, and the Haribon Foundation for the Conservation of Natural Resources, Inc., also participated in the case. Oral arguments were heard on the matter.

ISSUES:

  1. Constitutionality of R.A. 8371 Provisions, Specifically Regarding State Ownership Over Lands and Natural Resources

    • Whether the sections of R.A. 8371, known as the Indigenous Peoples Rights Act of 1997, specifically Sections 3, 5, 6, 7, 8, 57, and 58, among others, violate the Constitution by granting ownership and rights over natural resources to indigenous peoples, conflicting with the Regalian Doctrine in Section 2, Article XII of the Constitution.

  2. Violation of Private Landowners' Rights

    • Whether the definition of "ancestral domains" and "ancestral lands" in Sections 3(a) and 3(b) of R.A. 8371 infringes upon the rights of private landowners.

  3. Due Process and NCIP’s Powers and Jurisdiction

    • Whether Sections 51-53, 59, 63, 65, and 66 of R.A. 8371, which detail processes and jurisdiction of the National Commission on Indigenous Peoples (NCIP) and apply customary law to disputes, violate the due process clause of the Constitution.

  4. Presidential Control Over Executive Departments

    • Whether Rule VII, Part II, Section 1 of NCIP Administrative Order No. 1, Series of 1998, which defines the relationship of the NCIP to the Office of the President as a "lateral but autonomous relationship," infringes on the President’s power of control over executive departments under Section 17, Article VII of the Constitution.

RULING:

The Supreme Court was equally divided (7-7) on these issues, hence, the petition was dismissed in accordance with Rule 56, Section 7 of the Rules of Civil Procedure, which states that when the Court is equally divided in opinion, the petition shall be dismissed. As a result, the challenged provisions of R.A. 8371 remain effective.

PRINCIPLES:

  1. Regalian Doctrine The concept that all lands of the public domain and natural resources are owned by the State, as embodied in Section 2, Article XII of the Constitution.

  2. Parens Patriae The principle that the State must protect the rights of those who are unable to protect themselves, such as indigenous peoples.

  3. Justiciability and Legal Standing The doctrine requiring that petitioners must show a direct, personal interest in the case in order to have standing to sue.

  4. Equal Division Rule As per Rule 56, Section 7 of the Rules of Civil Procedure, when the Court is equally divided in opinion, the case is dismissed.

  5. Due Process Clause The constitutional guarantee that legal proceedings will be fair and that individuals will be given notice and an opportunity to be heard.

  6. Autonomy within Executive Departments The principle of delineating the relationship and control between newly created agencies and existing executive departments under the President’s control.