Title
Atlas Consolidated Mining and Development Corporation vs. Factoran Jr.
Case
G.R. No. L-75501
Decision Date
Sep 15, 1987
Atlas and Buqueron disputed overlapping mining claims. Buqueron's timely appeal upheld his claims, except overlapping areas, affirming administrative findings supported by substantial evidence.
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Case Digest (G.R. No. L-75501)

Facts:

  1. Registration of Mining Claims:

    • On February 9, 1972, Atlas Consolidated Mining and Development Corporation (Atlas) registered its "Master VII Fr." mining claim with the Mining Recorder of Toledo City.
    • On September 10, 1973, private respondent Asterio Buqueron registered the declarations of location of his "St. Mary Fr." and "St. Joseph Fr." mining claims with the same Mining Recorder.
    • On October 15, 1973, Atlas registered the declarations of location of its "Carmen I Fr." to "Carmen V Fr." mining claims with the same Mining Recorder.
  2. Survey and Lease Application:

    • Buqueron's "St. Mary Fr." and "St. Joseph Fr." mining claims were surveyed, and the survey plans were approved by the Director of Mines and Geo Sciences.
    • Notice of Buqueron's lease application was published in the February 22 and 28, 1977 issues of the Evening Post.
  3. Adverse Claim by Atlas:

    • During the publication period, Atlas filed an adverse claim against Buqueron's mining claims, alleging that they overlapped with its own mining claims.
  4. Administrative Decisions:

    • The Director of Mines rendered a decision on April 17, 1978, granting Buqueron preferential rights to his mining claims, except for the area overlapping with Atlas's "Master VII Fr." claim.
    • Atlas appealed to the Minister of Natural Resources, who reversed the Director of Mines' decision on November 10, 1978, declaring Buqueron's claims null and void and upholding Atlas's claims.
    • Buqueron appealed to the Office of the President, which reinstated the Director of Mines' decision, prompting Atlas to file this petition.

Issue:

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Ruling:

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Ratio:

  1. Timeliness of Appeal:

    • Under Section 31 of the Revised Administrative Code, if the last day for filing an appeal falls on a legal holiday, the act may be done on the next business day. This principle applies to the filing of appeals in administrative cases.
  2. Validity of Mining Claims:

    • Administrative findings of fact are binding if supported by substantial evidence. The Court will not reexamine the sufficiency of evidence unless there is a clear showing of arbitrariness, capriciousness, or grave abuse of discretion. In this case, the Director of Mines' findings were supported by substantial evidence, and the Office of the President correctly affirmed them.

Conclusion:

The Supreme Court denied Atlas's petition and affirmed the decision of the Office of the President, upholding the validity of Buqueron's mining claims except for the overlapping area with Atlas's "Master VII Fr." claim. The Court emphasized the importance of respecting administrative findings of fact supported by substantial evidence and the proper application of procedural rules regarding the timeliness of appeals.


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