Calanza v. Paper Industries Corporation of the Philippines
REITERATIONFacts
1. The Antecedents: Petitioners applied for and were issued small-scale mining permits by the Governor of Davao Oriental for areas within the logging concession of respondent Paper Industries Corporation of the Philippines (PICOP). PICOP denied petitioners entry, asserting exclusive rights to the area and questioning the validity of the permits due to their location in Surigao del Sur and being issued over areas covered by forest rights (Timber License Agreements). Petitioners filed a complaint for injunction, seeking to compel PICOP to allow them access to the mining sites. 2. Procedural History: The Regional Trial Court (RTC) of Banganga, Davao Oriental, ruled in favor of the petitioners, declaring their right to extract gold and enjoining PICOP from preventing their entry. The RTC found the mining areas to be within Davao Oriental and that the governor had the authority to issue the permits. PICOP appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's decision, finding that the RTC erred in resolving the boundary dispute and that the governor lacked the authority to issue small-scale mining permits under Republic Act No. 7076, which vests such power in the Provincial Mining Regulatory Board. The CA dismissed petitioners' complaint, and their subsequent motion for reconsideration was denied. 3. The Petition: Petitioners seek review of the Court of Appeals' decision under Rule 45 of the Rules of Court. They argue that the CA erred in reversing the RTC's ruling. The core of the dispute involves the validity of the small-scale mining permits issued by the governor and the jurisdiction of the RTC to rule on the boundary dispute. Petitioners contend that the permits are valid and that they have the right to access the mining areas, while respondents maintain that the permits are void and that the RTC lacked jurisdiction over the boundary issue.
Issue(s)
Whether the RTC has jurisdiction over the boundary dispute between Davao Oriental and Surigao del Sur. Whether the small-scale mining permits issued by the governor of Davao Oriental are valid. Whether PICOP has the right to deny petitioners access to the mining areas.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed, upholding the reversal of the RTC decision and the dismissal of the complaint.
Ratio Decidendi
On the RTC's jurisdiction over the boundary dispute: The Court held that the RTC has no original jurisdiction over boundary disputes between local government units (LGUs). Section 118 of the Local Government Code of 1991 vests the power to settle such disputes in the respective Sanggunians. The RTC only has appellate jurisdiction over decisions of the Sanggunian concerning boundary disputes, as provided in Section 119 of the same Code. In this case, no decision from the Sanggunians was appealed to the RTC, and the RTC did not have original jurisdiction to decide the boundary issue. Therefore, the RTC's decision on the boundary dispute was a nullity for want of jurisdiction. The Court reiterated that a judgment rendered by a court without jurisdiction is void and may be attacked anytime, producing no legal effect. On the validity of the small-scale mining permits: The Court affirmed the CA's finding that the permits were legally questionable. Under Presidential Decree No. 1899 and subsequently Republic Act No. 7076 (which took effect on July 18, 1991, and thus governed the petitioners' applications filed on August 23, 1991), the authority to approve small-scale mining permits is vested in the Provincial/City Mining Regulatory Board, not the provincial governor. The Board is composed of representatives from the DENR, the small-scale mining sector, the big-scale mining industry, and an environmental group. Since the governor lacked the legal authority to issue these permits, the permits were declared null and void. On PICOP's right to deny access: Based on the findings that the RTC had no jurisdiction over the boundary dispute and that the petitioners' small-scale mining permits were null and void, the Court concluded that the petitioners had no right to enter and conduct mining operations within the disputed lands. Consequently, PICOP was correct in denying them access.
Main Doctrine
A Regional Trial Court (RTC) has no original jurisdiction over boundary disputes between local government units; such power is vested in the respective Sanggunians. An RTC only has appellate jurisdiction over decisions of the Sanggunian concerning boundary disputes. Furthermore, small-scale mining permits must be issued by the Provincial/City Mining Regulatory Board, not by the provincial governor.