MR Holdings, Inc. v. De Jesus
REITERATIONFacts
The Antecedents: Onephil Mineral Resources, Inc. (Onephil) filed an Exploration Permit Application (EPA) covering an area in Marinduque. The Mines and Geo-Sciences Bureau (MGB) found that Onephil's application overlapped with existing mining applications, claims, and a portion of the Marinduque Wildlife Sanctuary. Onephil amended its application to exclude these areas. Marcopper Mining Corporation (Marcopper), operator of the San Antonio Copper Project (SACP), had a pending application for a Mineral Production Sharing Agreement (MPSA) and notified the MGB that areas covered by SACP are closed to mining applications. Onephil subsequently amended its EPA, and the MGB issued an Area Status and Clearance stating the applied area was open to mining applications. Marcopper sought to expand its MPSA, but the MIMAROPA Area Status report showed conflicts with several Exploration Permit Applications, including Onephil's. The MGB rejected Marcopper's claim and denied the amendment of its MPSA application due to conflicts with Onephil's EPA. Procedural History: Aggrieved, Marcopper filed a Petition for Prohibition and Mandamus with the Regional Trial Court (RTC) against the MGB OIC Regional Director, later amending it to include the DENR Regional Executive Director. The RTC initially denied the prayer for injunction but later denied a Motion to Dismiss filed by respondents, ruling it had jurisdiction. Respondents filed a petition for certiorari with the Court of Appeals (CA), which was dismissed. The Supreme Court affirmed the CA's dismissal in G.R. No. 188229. Subsequently, the RTC, after trial, dismissed the amended petition, ruling that the issue involved a mining dispute within the exclusive jurisdiction of the Panel of Arbitrators. The CA affirmed the RTC's dismissal, holding that the case involved factual matters requiring technical knowledge of mining authorities and thus constituted a mining dispute. The CA also stated that petitioners had an adequate remedy under RA 7942 by filing a complaint with the Panel of Arbitrators. The Petition: Petitioners seek a review of the CA's decision, arguing that the Court of Appeals committed serious errors of law in ruling that the issue is a mining dispute, in defying the Supreme Court's resolution in G.R. No. 188229 which allegedly upheld the RTC's jurisdiction, and in failing to recognize that Onephil, as a mere applicant, does not possess mining rights and thus does not fall within the categories of parties to a dispute under the Panel of Arbitrators' jurisdiction. They contend that the issue is the refusal of government officials to comply with Section 19 of RA 7942, making it a proper subject for prohibition and mandamus.
Issue(s)
Whether the dispute is within the jurisdiction of the Panel of Arbitrators. Whether the Supreme Court's resolution in G.R. No. 188229 already settled the issue of jurisdiction with finality.
Ruling
The Petition is denied. The Panel of Arbitrators has jurisdiction over the dispute.
Ratio Decidendi
On the issue of jurisdiction of the Panel of Arbitrators: The Court held that the nature of an action and the tribunal's jurisdiction are determined by the material allegations of the complaint, the law in force, and the character of the relief sought. In this case, despite the petition being couched as one for prohibition and mandamus, the material allegations in the Amended Petition and the reliefs sought indubitably show that the case involves a dispute over the conferment of mining rights to Onephil, which falls within the exclusive and original jurisdiction of the Panel of Arbitrators under Section 77 of the Philippine Mining Act (RA 7942). The Court emphasized that the dispute squarely falls under Section 77(a) as it involves a dispute relative to Onephil's application for an exploration permit. The procedural steps outlined in the Philippine Mining Act and its Implementing Rules and Regulations for filing protests or oppositions to exploration permit applications, which are to be resolved by the Panel of Arbitrators, were also detailed. The Court concluded that by filing a petition for mandamus and prohibition instead of following the prescribed procedure, petitioners attempted to circumvent the jurisdiction of the Panel of Arbitrators, which the Court cannot allow. On the issue of whether G.R. No. 188229 settled the jurisdiction: The Court reiterated that the issue of jurisdiction can be raised at any time, even after final judgment, as it is conferred by law and cannot be set aside by the parties or the courts. The Court clarified that its dismissal of the petition in G.R. No. 188229 was a summary dismissal by the CA, which was affirmed by the Supreme Court, and did not delve into the merits of the jurisdiction issue. Therefore, the RTC's earlier order denying the motion to dismiss, which was the subject of G.R. No. 188229, was interlocutory and did not attain finality on the issue of jurisdiction. The subsequent dismissal by the RTC, after trial, correctly ruled on the lack of jurisdiction, which was then affirmed by the CA. The Court stressed that it cannot conveniently set aside the fact that the Philippine Mining Act conferred jurisdiction over the dispute to the Panel of Arbitrators.
Main Doctrine
The jurisdiction over disputes involving rights to mining areas, mineral agreements or permits, and surface owners, occupants, and claimholders/concessionaires falls exclusively with the Panel of Arbitrators under Section 77 of Republic Act No. 7942 (The Philippine Mining Act of 1995), and not with the Regional Trial Court.