Case Digest (G.R. No. 206728)
Facts:
The case involves a dispute between Apo Cement Corporation (Apocemco) as the petitioner and Mingson Mining Industries Corporation (Mingson) as the respondent, concerning mining claims known as Allied 1 and 2, and Lapulapu 31 and 32. The conflict arose when Apocemco submitted a Mineral Production Sharing Agreement (MPSA) proposal to the Department of Environment and Natural Resources (DENR) on June 19, 1991, seeking to take over the claims held by Luvimin Cebu Mining Corporation (Luvimin), which had allegedly failed to develop the mineral properties. On August 18, 1992, and March 2, 1993, the DENR Regional Office declared the subject mining claims abandoned and open for location, prompting Luvimin to appeal. Mingson contested these declarations, asserting that its own mining claims, specifically Yellow Eagle I to VII, overlapped with the subject claims. Mingson claimed that its Yellow Eagle IV was registered on February 7, 1983, overlapping with Allied 1 and 2, while Yellow Ea...
Case Digest (G.R. No. 206728)
Facts:
Background of the Dispute
The case involves a dispute over mining claims known as "Allied 1 and 2" and "Lapulapu 31 and 32" between petitioner Apo Cement Corporation (Apocemco) and respondent Mingson Mining Industries Corporation (Mingson). Apocemco sought to take over these claims from their current holder, Luvimin Cebu Mining Corporation (Luvimin), due to the latter's alleged failure to develop and utilize the mineral properties.
DENR Declarations and Overlapping Claims
On August 18, 1992, and March 2, 1993, the DENR Central Visayas, Region 7 Office declared the subject mining claims abandoned and open for location by other parties. Mingson contested these declarations, asserting that its own mining claims, "Yellow Eagle I to VII," overlapped with the subject claims. Specifically, Mingson claimed that its "Yellow Eagle IV" and "Yellow Eagle III" claims overlapped with "Allied 1 and 2" and "Lapulapu 31 and 32," respectively.
DENR Proceedings
On March 1, 1995, the DENR Regional Office awarded portions of the subject mining claims to Mingson, finding that Apocemco's claims encroached on Mingson's "Yellow Eagle" claims. However, upon Apocemco's motion for reconsideration, the DENR Regional Office reversed its decision on September 5, 1995, recommending that the claims be awarded to Apocemco, subject to the outcome of Luvimin's appeal.
POA Decision
The Panel of Arbitrators (POA) upheld the DENR Regional Office's decision on May 3, 1996, without requiring the parties to file pleadings or holding a hearing. Mingson appealed this decision to the DENR Mines Adjudication Board (MAB), arguing that the POA's decision was arbitrary and violated due process.
MAB and CA Rulings
The DENR MAB reversed the POA's decision on July 31, 2007, finding that Mingson was denied due process. The Court of Appeals (CA) affirmed the MAB's decision on June 13, 2012, holding that the POA failed to follow the procedures under DENR DAO 95-23 and that Apocemco failed to perfect its appeal.
Issue:
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Ruling:
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Ratio:
Due Process in Administrative Proceedings: The Court emphasized that due process is a fundamental right that must be observed in all administrative and judicial proceedings. The POA's failure to follow the procedures under DENR DAO 95-23, which required hearings and opportunities for the parties to be heard, rendered its decision null and void.
Jurisdictional Issue: A violation of due process raises a jurisdictional issue, and decisions rendered without due process are void ab initio. The Court cited PO2 Montoya v. Police Director Varilla, stating that such violations oust tribunals of their jurisdiction.
Administrative Flexibility: The DENR MAB, as an administrative body, is not bound by strict procedural rules and may consider issues raised informally, such as in Mingson's August 8, 1996 letter. The Court upheld the MAB's decision to address the due process issue despite its informal presentation.
Procedural Compliance: The Court found that Apocemco failed to comply with Sections 5 and 7 of Rule 43 of the Rules of Court, which require proper service of the petition and proof of service. This failure was a sufficient ground for dismissing the appeal.
Conclusion:
The Supreme Court affirmed the CA's dismissal of Apocemco's appeal, upholding the DENR MAB's ruling that Mingson was denied due process. The Court reiterated the importance of due process in administrative proceedings and the necessity of complying with procedural rules in appeals.