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IPRA (R.A. No.

8371)
1. Cruz vs Secretary
(347 SCRA 128, G.R. No. 135385, December 6, 2000)
ISAGANI CRUZ and CESAR EUROPA, petitioners, vs. SECRETARY OF ENVIRONMENT AND
NATURAL RESOURCES,
SECRETARY OF BUDGET AND MANAGEMENT and CHAIRMAN and COMMISSIONERS OF THE
NATIONAL
COMMISSION ON INDIGENOUS PEOPLES,respondents.
FACTS:
Cruz, a noted constitutionalist, assailed the validity of the RA 8371 or the Indigenous Peoples Rights Act
on the ground that the law 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. The IPRA law basically enumerates the rights of the indigenous peoples
over ancestral domains which may include natural resources. Cruz et al contend that, by providing for an
allencompassing
definition of ancestral domains and ancestral lands which might even include private lands
found within said areas, Sections 3(a) and 3(b) of said law violate the rights of private landowners.
ISSUE: WON IPRA law is unconstitutional. NO
HELD:
The SC deliberated upon the matter. After deliberation they voted and reached a 7-7 vote. They
deliberated again and the same result transpired. Since there was no majority vote, Cruzs petition was dismissed
and the IPRA law was sustained. Hence, ancestral domains may include public domain somehow against the
regalian doctrine.

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