Macawiwili Gold Mining and Development Co., Inc. v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Philex Mining Corporation filed a complaint for expropriation against Macawiwili Gold Mining and Development Co., Inc. and Omico Mining & Industrial Corporation, seeking to expropriate 21.9 hectares of petitioners' mining areas. This action stemmed from a prior Supreme Court decision that recognized the possessory rights of Macawiwili and Omico over these claims, despite Philex Mining having existing improvements on the surface, including roads, a motorpool, a tailings dam, and bunkhouses. The trial court noted that Philex Mining's attempt to expropriate the land after the Supreme Court's ruling appeared to be a last-ditch effort to evade the consequences of that decision and constituted forum-shopping. 2. Procedural History: The Regional Trial Court (RTC) initially denied Philex Mining's application for a preliminary injunction. Subsequently, on February 18, 1993, the RTC dismissed Philex Mining's complaint, finding that to grant the expropriation would defy the Supreme Court's decision and encourage forum-shopping. Philex Mining moved for reconsideration, which was denied, and then appealed to the Court of Appeals (CA). Petitioners filed a Motion to Dismiss the appeal with the CA, arguing that only questions of law were involved and the appeal should have been filed directly with the Supreme Court. The CA denied this motion on April 12, 1994. Petitioners then filed the instant petition for certiorari with the Supreme Court. 3. The Petition: Petitioners Macawiwili Gold Mining and Development Co., Inc. and Omico Mining and Industrial Corporation filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to set aside the CA's resolution denying their motion to dismiss the appeal. They argued that the CA committed a grave abuse of discretion by denying the motion, as Philex Mining's appeal raised only questions of law regarding its right to expropriate under Presidential Decree No. 463, and thus should have been filed directly with the Supreme Court via a petition for review on certiorari under Rule 45, not an ordinary appeal to the CA. The Supreme Court agreed that the issues presented by Philex Mining's appeal were legal in nature, concerning the interpretation of P.D. 463 and the propriety of expropriation in this context, and therefore the CA erred in not dismissing the appeal.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in denying petitioners' Motion to Dismiss Appeal. Whether the issues raised in Philex Mining's appeal to the Court of Appeals were questions of law or questions of fact; and the proper mode of appeal for questions of law, including exceptions to the rule requiring a motion for reconsideration.
Ruling
The petition is GRANTED. The challenged resolution of the Court of Appeals is SET ASIDE, and the appeal of respondent Philex Mining is DISMISSED.
Ratio Decidendi
On the issue of whether the Court of Appeals committed grave abuse of discretion in denying petitioners' Motion to Dismiss Appeal: The Supreme Court held that the Court of Appeals committed a grave abuse of discretion. Certiorari lies when a court, in denying a motion to dismiss, acts without or in excess of jurisdiction or with grave abuse of discretion. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction, or an arbitrary or despotic manner of acting. On the issue of whether the issues raised in Philex Mining's appeal to the Court of Appeals were questions of law or questions of fact; and the proper mode of appeal for questions of law, including exceptions to the rule requiring a motion for reconsideration: The Supreme Court determined that the issues raised by Philex Mining in its appeal to the Court of Appeals were purely questions of law. These issues pertained to the interpretation of Section 59 of Presidential Decree No. 463, specifically whether Philex had the right to expropriate mining areas belonging to another mining company, whether such expropriation was absurd, whether Philex was guilty of forum-shopping, and whether the expropriation would divide surface and subsurface rights. The Court emphasized that these questions did not require an examination of the probative value of evidence but rather a determination of what the law is on a given set of facts. The Court reiterated the rule that appeals from judgments of Regional Trial Courts in the exercise of their original jurisdiction, where only questions of law are raised, must be brought directly to the Supreme Court by a petition for review on certiorari under Rule 45. The Court cited Supreme Court Circular No. 2-90 and Rule 41, Section 2 of the 1997 Rules of Civil Procedure to support this procedural requirement. The Court noted that the Court of Appeals should have dismissed the appeal, as it was filed by the wrong mode. The Court found that petitioners' failure to file a motion for reconsideration before the Court of Appeals was not fatal to their petition for certiorari. This was because the issues raised in the petition were substantially the same as those asserted in their Motion to Dismiss Appeal before the CA, and the CA had already passed upon them. The Court stated that the rule requiring exhaustion of remedies does not call for an exercise in futility.
Main Doctrine
An appeal raising purely questions of law from a Regional Trial Court's judgment in the exercise of its original jurisdiction must be filed directly with the Supreme Court via a petition for review on certiorari, not an ordinary appeal to the Court of Appeals. The Court of Appeals commits grave abuse of discretion in denying a motion to dismiss such an appeal.