G.R. No. 229413 - Agata Mining Ventures, Inc. vs. Heirs of Alaan

Respondents are the registered owners of a 14.22-hectare parcel of land located at Payong Payong, Tiningbasan, Tubay, Agusan del Norte (the subject property).
Petitioner Agata Mining Ventures, Inc. (petitioner) entered into an Operating Agreement with Minimax Mineral Exploration Corporation (Minimax), the latter being the holder of Mineral Production Sharing Agreement (MPSA) No. 134-99-XIII with the Philippine government, represented by the DENR Secretary.

On May 26, 1999, Minimax entered into MPSA No. 134-99-XIII with the government to conduct mining operations covering areas including the subject property.
On June 20, 2014, Minimax executed an Operating Agreement with petitioner granting the latter exclusive rights to explore, develop, and operate the mining area, which included the subject property.
This Operating Agreement was registered with the DENR Mines and Geosciences Bureau (MGB) Regional Office No. XIII and approved by the MGB Quezon City (September 18, 2014) and subsequently by the DENR Secretary through the MGB Director (June 21, 2016).

Petitioner considered the subject property suitable for a sedimentation pond essential to mining operations.
Petitioner offered to buy the property at P175,000.00 per hectare, but respondents refused the offer.
On December 4, 2014, petitioner filed a complaint for expropriation with a prayer for issuance of a writ of possession against respondents before the RTC, Branch 34, Cabadbaran City.
Respondents moved to dismiss the case, claiming the petitioner lacked authority to exercise eminent domain.

The RTC issued an Omnibus Resolution on June 26, 2015, granting the writ of possession to petitioner and ordering the sheriff to place petitioner in possession of the subject property.
Respondents moved for reconsideration, which the RTC denied on October 30, 2015.
Respondents filed a petition for certiorari with the Court of Appeals (CA).

The CA, in a decision dated September 16, 2016, held that the Operating Agreement was a civil contract between private parties and did not confer authority on petitioner to exercise eminent domain.
The CA nullified the writ of possession issued by the RTC, emphasizing the constitutional principle of non-delegation of inherent state powers such as eminent domain.
Petitioner’s motion for reconsideration before the CA was denied (Resolution dated January 9, 2017).

Petitioner filed a Petition for Review on Certiorari before the Supreme Court.
Core contentions include the limited scope of the trial court in issuing writs of possession, the authority given to qualified mining operators under Sections 75 and 76 of Republic Act No. 7942 (Philippine Mining Act of 1995) to exercise eminent domain, and the validity of the transfer of mining rights from Minimax to petitioner.

Whether petitioner has the legal authority to file a complaint for expropriation of the subject property, i.e., whether petitioner may exercise the power of eminent domain in the context of mining operations under Philippine law.