**Facts:**
This case involves a dispute over ancestral land titles issued in favor of Maximo Bugnay, Sr., which were contested by Gabriel Diclas et al., composed of members from the Ibaloi and Kankana-ey tribes in Benguet Province. Both parties claim long-term possession and ownership of the disputed parcels of land located in Pinsao, Baguio City. While Diclas et al. assert ancestral land ownership tracing back to a certain Bilag, recognized through Proclamation No. 401, Bugnay, Sr. counterclaims ancestral land ownership tracing back to his great grandfather, Belting. The dispute emerged after the issuance of four certificates of ancestral land title to Bugnay, Sr. by the National Commission on Indigenous Peoples (NCIP) in 2007, which Diclas et al. sought to cancel on grounds of alleged fraud and procedural irregularities in the acquisition.
The NCIP denied the petition for cancellation, leading Diclas et al. to file a review petition with the Court of Appeals, which also sided with the NCIP. Claiming both substantive and procedural issues, including alleged fraud by Bugnay, Sr. and violation of their right to due process, Diclas et al. escalated the matter to the Supreme Court.
**Issues:**
1. Whether Bugnay, Sr. committed fraud in securing his ancestral land titles.
2. Whether the CA erred in ruling against Diclas et al.’s claim of vested rights over the disputed lands.
3. Whether publication alone suffices to confer NCIP jurisdiction over ancestral land claims.
4. Whether Bugnay, Sr.’s supposed procedural non-compliance during his ancestral land claim invalidated the process, violating Diclas et al.’s right to due process.
**Court’s Decision:**
The Supreme Court denied Diclas et al.’s petition, affirming the CA’s decision. It reasoned that the issues raised by Diclas et al. mainly involved factual matters beyond the purview of a Rule 45 review. It stated that administrative findings by the NCIP, being a specialized body in indigenous people’s affairs, are given weight unless proven otherwise, which Diclas et al. failed to substantiate. Upon these grounds, the Court found no fraud by Bugnay, Sr., no error by the CA in its rulings, and adjudged that Bugnay, Sr. had substantially complied with the Indigenous Peoples’ Rights Act requirements for ancestral land claims. The appeal was viewed as lacking evidence to overturn the CA and NCIP’s decisions.
**Doctrine:**
1. The factual findings of administrative agencies, like the NCIP, are accorded great weight and respect, especially when supported by substantial evidence, except in cases of clear arbitrariness or misapprehension of facts.
2. Rights over properties are deemed vested when they are established, undisputed, and recognized by lawful means. The claimants failed to prove a vested right over the disputed parcels.
3. Compliance with publication requirements under the Indigenous Peoples’ Rights Act is deemed substantial when the essential steps to inform concerned parties are reasonably undertaken, even if not to the full extents contested by the opposing party.
**Class Notes:**
– Rule 45 petitions: Limits appeals to questions of law, not fact.
– Administrative agency findings: Weighted heavily unless shown to be arbitrary or misapprehended.
– Vested rights: Defined as rights that are definitive and undisputed, established through proper legal recognition.
– Fraud in legal proceedings: Requires concrete evidence to be proven; unsubstantiated allegations are insufficient.
– Indigenous Peoples’ Rights Act compliance: Relates to the process of delineation, recognition, and titling of ancestral lands, requiring publication and/or posting as essential procedural steps for jurisdictional purposes.
**Historical Background:**
This case reflects the complex interplay between indigenous peoples’ rights to ancestral lands and the legal frameworks established to recognize and protect these rights in the Philippines. It underscores the importance of adhering to procedural requirements set forth in the Indigenous Peoples’ Rights Act, both for claimants and the administrative bodies processing these claims, and signifies the courts’ deference to specialized administrative bodies like the NCIP in assessing factual matters within their expertise.
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