10/12/2019 E-Library - Information At Your Fingertips: Printer Friendly injunction is directed are violative of said right. Proclamation No. 15, however, does not appear to be a definitive recognition of private respondents ancestral land claim. The proclamation merely identifies the Molintas and Gumangan families, the predecessor-in-interest of private respondents, as claimants of a portion of the Busol Forest Reservation but does not acknowledge vested rights over the same. xxxx The fact remains, too, that the Busol Forest Reservation was declared by the Court as inalienable in Heirs of Gumangan v. Court of Appeals. The declaration of the Busol Forest Reservation as such precludes its conversion into private property. Relatedly, the courts are not endowed with jurisdictional competence to adjudicate forest lands.[34] In City Government of Baguio, it was recognized that the NCIP is empowered to issue TROs and writs of injunction. Nevertheless, the said case ruled that therein respondents were not entitled to an injunctive relief because they failed to prove their definite right over the properties they claimed. The circumstances in City Government of Baguio and the present case are similar. In both cases, the claimants principally rely on Proclamation No. 15 as basis for their ancestral land claims in the Busol Forest Reserve. Unfortunately, it was ruled that the said proclamation is not a definitive recognition of their ancestral land claims as it only identifies their predecessors-in-interest as claimants. Thus, it is quite unfortunate that the CA found that the actions of the NCIP were in accordance with law. A cursory reading of the decision indicates that it merely relied on the applicable statute without regard to the doctrines and principles settled by the Court. The pronouncements in City Government of Baguio should have put the appellate court on notice that the actions of the NCIP were baseless because it settled that claimants of lands in the Busol Water Reserve cannot rely on anticipatory claims for the issuance of the preventive writ. It befuddles the Court why the CA did not bother to address the said ruling in its discussions and perfunctorily relied on the statute alone. On the other hand, respondents argue that petitioners erred in relying on City Government of Baguio in that res judicata did not arise considering that they were not parties to the said case and that only parties may be bound by the decision. Nevertheless, while res judicata may be inapplicable, the ruling in City Government of Baguio still finds relevance under stare decisis. The said doctrine states that when the Court has once laid down a principle of law as applicable to a certain state of facts, it will adhere to that principle and apply it to all future cases where facts are substantially the same, regardless whether the parties and property are the same.[35] Stare decisis differs from res judicata in that the former is based upon the legal principle or rule involved while the latter is based upon the judgment itself.[36] elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/64367 9/13