Atlas Consolidated Mining and Development Corporation v. Factoran, Jr.
REITERATIONFacts
The Antecedents: Atlas Consolidated Mining and Development Corporation (Atlas) registered its "Master VII Fr." mining claim on February 9, 1972. Asterio Buqueron (Buqueron) registered his "St. Mary Fr." and "St. Joseph Fr." mining claims on September 10, 1973. Atlas registered its "Carmen I Fr." to "Carmen V. Fr." claims on October 15, 1973. Buqueron's claims were surveyed and approved, and his lease application was published. Atlas filed an adverse claim against Buqueron's claims due to alleged overlap. Procedural History: The Director of Mines, in a decision dated April 17, 1978, granted Buqueron preferential right to the disputed areas, except for the portion overlapping with Atlas' "Master VII Fr." claim, to which Atlas was given preferential right. The Minister of Natural Resources, on appeal, set aside the Director's decision, declared Buqueron's claims null and void, and granted Atlas preferential right to its "Carmen" claims. The Deputy Executive Secretary, on further appeal, reversed the Minister's decision and reinstated the Director's decision. The Petition: Atlas filed a petition for review on certiorari, seeking to set aside the decision of the Deputy Executive Secretary.
Issue(s)
Whether the appeal filed by private respondent Buqueron to the Office of the President was time-barred. Whether there was a valid location and discovery of the disputed mining claims.
Ruling
The petition is devoid of merit. The assailed decision of the Office of the President is affirmed.
Ratio Decidendi
On Issue 1: Whether the appeal filed by private respondent Buqueron to the Office of the President was time-barred: The Court held that the appeal was filed on time. Private respondent Buqueron received the decision of the Minister of Natural Resources on November 27, 1978. Under Section 50 of Presidential Decree No. 463, the appeal to the Office of the President must be filed within five (5) days from receipt. The five-day period expired on December 2, 1978, a Saturday. Section 31 of the Revised Administrative Code provides that where the last day for doing an act falls on a holiday, the act may be done on the next succeeding business day. Since Saturday was observed as a legal holiday in the Office of the President, and December 4, 1978, was the next succeeding business day (Monday), the appeal filed on December 4, 1978, was timely. This Court has consistently held that acts required to be done on a holiday may be performed on the next business day, citing cases such as Gonzaga vs. Ce David and Calano vs. Cruz. On Issue 2: Whether there was a valid location and discovery of the disputed mining claims: The Court affirmed the findings of fact of the administrative bodies, holding that such findings, when supported by substantial evidence, are binding upon the courts. The Director of Mines found that Buqueron's claims were validly located and surveyed, supported by affidavits of his authorized agent and geodetic engineer, and maps showing ingress and egress points that would allow for location and survey without being noticed by Atlas. The Director of Mines concluded that Atlas failed to adduce sufficient evidence to nullify Buqueron's prior claims, giving prima facie evidentiary value to Buqueron's sworn declarations of location. The Director also found that Atlas' subsequent claims, insofar as they conflicted with Buqueron's prior claims, were null and void, but Buqueron's claims were also null and void insofar as they conflicted with Atlas' prior "Master VII Fr." claim. The Court reiterated that judicial review of administrative decisions is limited to cases of denial of due process, mistake of law, fraud, collusion, arbitrary action, palpable errors, or grave abuse of discretion. In this case, the records showed no such circumstances justifying the overturning of the findings of fact of the Director of Mines, which were affirmed by the Office of the President. Substantial evidence, defined as "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion," was sufficient to support the administrative findings, as held in Ang Tibay vs. Court of Industrial Relations.
Main Doctrine
When the last day for filing an appeal falls on a Saturday, which is a legal holiday, the appeal may be filed on the next succeeding business day (Monday) as provided under Section 31 of the Revised Administrative Code. Findings of fact by administrative bodies, if supported by substantial evidence, are binding upon the courts.