Santa Rosa Mining Company, Inc. v. Leido
REITERATIONFacts
The Antecedents: Petitioner Santa Rosa Mining Company, Inc. (petitioner) is the holder of fifty (50) mining claims located under the Philippine Bill of 1902. On October 14, 1977, Presidential Decree No. 1214 was issued, requiring holders of subsisting and valid patentable mining claims located under the Philippine Bill of 1902 to file a mining lease application within one year from its approval. Petitioner filed a mining lease application under protest on October 13, 1978, with a reservation that it was not waiving its rights until the validity of PD 1214 was passed upon by the Supreme Court. Procedural History: Petitioner filed a special civil action for certiorari and prohibition, assailing PD 1214 as unconstitutional for allegedly amounting to deprivation of property without due process. Petitioner cited prior Court of First Instance (CFI) decisions in land registration cases initiated by third parties, which allegedly declared its mining claims as private property. Respondents, however, argued that petitioner failed to exhaust administrative remedies, citing the pendency of petitioner's appeal with the Office of the President regarding the Secretary of Natural Resources' ruling that 44 of its claims were void for lack of valid "tie points" and that all claims were abandoned and cancelled for non-compliance with the Philippine Bill of 1902 and Executive Order No. 141. The Petition: Petitioner seeks to declare Presidential Decree No. 1214 unconstitutional and to enjoin its enforcement, alleging it deprives holders of vested rights without due process.
Issue(s)
Whether the petition should be dismissed for failure to exhaust administrative remedies. Whether the CFI decisions declaring petitioner's mining claims as private property preclude a determination of their validity and subsistence. Whether Presidential Decree No. 1214 is unconstitutional for allegedly amounting to deprivation of property without due process of law.
Ruling
The petition is dismissed. The temporary restraining order issued by the Court is lifted and set aside. Costs are against the petitioner.
Ratio Decidendi
On the failure to exhaust administrative remedies: The Court agreed with the respondents that it was premature to rule on the matter of abandonment of mining claims. Petitioner's appeal was still pending before the Office of the President. The Court reiterated the principle that a party cannot complain if courts do not act before the President decides an appeal, citing Ham v. Bachrach Motor Co., Inc. Thus, the attempt to seek judicial recognition of the continuing validity of its mining claims could not be entertained until the administrative remedies were exhausted. On the applicability of CFI decisions: The Court found the CFI decisions inapplicable. These decisions merely denied third parties' land registration applications over areas covered by petitioner's mining claims because the applicants failed to show registrable titles. While one CFI decision mentioned the claims as vested property, it did not squarely pass upon the issue of whether petitioner had continued to maintain these claims in compliance with applicable laws. This factual issue, concerning abandonment or forfeiture, was precisely what was pending before the Office of the President in DNR Case No. 4140. On the constitutionality of Presidential Decree No. 1214: The Court held that PD 1214 is constitutional, even assuming arguendo that petitioner was not bound to exhaust administrative remedies. The Decree was deemed a valid exercise of the State's sovereign power over lands of the public domain and national patrimony. The Court emphasized that mere location of a mining claim does not grant absolute ownership; it segregates the land from the public domain but does not grant indefeasible rights. Such rights, especially for unpatented claims, can be lost through abandonment or forfeiture. The Decree specifically targets claims where locators failed to obtain a patent, and even then, provides for renewable lease options under PD 463. The Court found PD 1214 to be in accord with Section 8, Article XIV of the 1973 Constitution and Section 2, Article XII of the 1987 Constitution, which declare natural resources as belonging to the State and subject to its full control and supervision.
Main Doctrine
Presidential Decree No. 1214 is a valid exercise of the State's sovereign power over lands of the public domain and national patrimony, and does not amount to deprivation of property without due process, especially when the mining claims involved are unpatented and potentially abandoned or forfeited. The principle of exhaustion of administrative remedies must be observed before challenging the constitutionality of such decrees.