Medrana v. Office of the President
NEW DOCTRINEFacts
The Antecedents: Private respondent Supreme Aggregates Corporation (Supreme Aggregates) was issued Mining Lease Contract (MLC) No. V-754 in 1969, covering 22 mining claims for volcanic cinder, etc., in Calamba, Laguna and Sto. Tomas, Batangas, with a 25-year lifetime. On May 14, 1976, within the period prescribed by Section 100 of P.D. No. 463, Supreme Aggregates filed an Application to Avail of Rights and Privileges under P.D. No. 463. On February 27, 1979, the Director of the Bureau of Mines denied this application for failure to submit Affidavits of Annual Work Obligations. On June 15, 1979, petitioner Teodoro Medrana was issued Quarry Temporary Permits (QTPs) Nos. 85, 86, and 87, covering areas within MLC No. V-754. On June 29, 1979, Supreme Aggregates filed a petition with the Director of Mines for reinstatement of its rejected application and cancellation of Medrana's QTPs. Procedural History: The Director of Mines, in a decision dated March 13, 1981, ordered the reinstatement of Supreme Aggregates' application and the cancellation of Medrana's QTPs. On appeal, the Minister of Natural Resources reversed this decision, reinstating Medrana's QTPs and declaring MLC No. V-754 lapsed due to Supreme Aggregates' failure to file the application to avail of rights under P.D. No. 463, which had become final. The Office of the President, in a decision dated September 20, 1988, reversed the Minister's decision, holding that failure to submit Affidavits of Annual Work Obligations did not automatically result in the cancellation of MLC No. V-754. The Petition: Petitioner Teodoro Medrana filed a Special Civil Action for Certiorari, assailing the decision of the Office of the President, alleging grave abuse of discretion amounting to lack of jurisdiction in reinstating MLC No. V-754 and cancelling his QTPs.
Issue(s)
Whether the Office of the President committed grave abuse of discretion amounting to lack of jurisdiction in reinstating Supreme Aggregates' Mining Lease Contract (MLC) No. V-754 and cancelling petitioner's Quarry Temporary Permits (QTPs). Whether the failure to submit Affidavits of Annual Work Obligations for two consecutive years constitutes automatic abandonment of a mining claim or lease under Section 27 of P.D. No. 463. Whether petitioner Medrana, as a registered owner of the superficies, has a preferential right to exploit quarry resources that would dissolve Supreme Aggregates' pre-existing rights. Whether Supreme Aggregates' petition for reinstatement and cancellation of QTPs was filed seasonably, considering the finality of the Director of Mines' denial order.
Ruling
The Supreme Court dismissed the Petition for Certiorari for lack of merit and affirmed the Decision dated September 20, 1988, of the Office of the President in toto. Costs against the petitioner.
Ratio Decidendi
On grave abuse of discretion: The Court concluded that petitioner failed to show that the Office of the President committed grave abuse of discretion or acted without or in excess of jurisdiction. Even if the Office of the President had misconstrued provisions of P.D. No. 463 or P.D. No. 309, such an error would be one of law or judgment, not correctible by certiorari. On the issue of abandonment and failure to submit Affidavits of Annual Work Obligations: The Court held that Section 27 of P.D. No. 463, as amended by P.D. No. 1385, provides that abandonment results from failure to comply with annual work obligations for two consecutive years. However, the precipitating event for lapse is the failure to carry out actual work, not merely the failure to submit the affidavit, which is only proof of compliance. The Court emphasized that to hold otherwise would exalt form over substance. The Director of Mines and the Office of the President found that Supreme Aggregates had, in fact, performed its annual work obligations. Therefore, there was no abandonment, automatic or voluntary, of MLC No. V-754. The Court cited Teodoro v. Macaraeg to define abandonment as requiring both intent and an external act expressing that intention, with an actual, absolute, and irrevocable desertion of rights or property, which were lacking in this case. On petitioner's preferential right: The Court acknowledged that under Section 67 of P.D. No. 463, petitioner Medrana, as a registered owner of the superficies, had a preferential right to exploit quarry resources. However, this right was merely preferential and ineffective to dissolve the pre-existing or subsisting right of Supreme Aggregates under MLC No. V-754. The denial order of the Director of Mines did not cancel or declare MLC No. V-754 abandoned, thus it did not open the area to new acquisitions. Consequently, petitioner's QTPs were not validly issued. On the finality of the Director of Mines' denial order: The Court ruled that Section 5 of P.D. No. 309, which provides a five-day period for appeal to the Secretary of Natural Resources and then to the President, applies only to cases involving conflicting mining claims. Since the Director of Mines' denial order on February 27, 1979, was issued when there were no conflicting claims asserted over Supreme Aggregates' leased area, and petitioner's QTPs were issued only three months later, P.D. No. 309 was inapplicable. The petition for reinstatement filed by Supreme Aggregates on June 29, 1979, was therefore seasonably filed. The Court reiterated that the denial order did not ipso facto cancel MLC No. V-754.
Main Doctrine
Failure to submit proof of compliance with annual work obligations does not automatically result in abandonment of a mining claim or lease if actual work was performed, as the submission of the affidavit is merely proof of compliance and not the performance itself. The Office of the President did not commit grave abuse of discretion in reinstating a mining lease contract despite the failure to submit affidavits of annual work obligations, provided actual work was performed.