Land Titles and Deeds IPRA Law vis a vis Regalian Doctrine

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 all-encompassing 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: Whether or not the IPRA law is unconstitutional.
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.