Case Digest (G.R. No. 34267-68)
Facts:
The case involves Biak-Na-Bato Mining Company (petitioner) against Hon. Arturo R. Tanco, Jr., in his capacity as the Secretary of Agriculture and Natural Resources, and Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc. (respondents). The dispute centers around 170 mining claims covering approximately 1,520 hectares located in the Cordillera Mountains, specifically in Pasil, Municipality of Balatoc, Province of Kalinga-Apayao. The mining claims were initially located between November 1933 and February 1934 by a group that included Jose Moldero and his relatives. Over the years, these claims were transferred to Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc. through various agreements and sales.
In 1956, both mining corporations underwent reconstitution proceedings to restore their mining claims, which were duly recognized by the Bureau of Mines. By 1968, both companies had engaged in various mining activities and had filed the necessary affidavits of annual assess...
Case Digest (G.R. No. 34267-68)
Facts:
Background of the Mining Claims
- In 1933, a group of individuals, including Jose Moldero, Saturnino Moldero, Miguel Moldero, and Manuel Dirige, located 170 mining claims in the Cordillera Mountains, Pasil, Balatoc, Kalinga-Apayao. These claims were divided into four groups: NAGASAT (42 claims), MUGAO (40 claims), LUCKY STRIKE (40 claims), and BUMABAG (48 claims).
- The claims were adjacent to the mining properties of Batong Buhay Gold Mines, Inc.
Transfer of Mining Rights
- On September 3, 1936, Balatoc-Lubuagan Mines Association entered into an Operating Agreement with Jose Moldero for the Nagasat and Mugao Groups.
- On September 19, 1936, Saturnino Moldero sold 20 claims of the Nagasat Group to Balatoc-Lubuagan Mines Association, and Miguel Moldero sold 7 claims.
- Balatoc-Lubuagan Mines, Inc. later acquired 52 claims and operating rights over 30 claims from various individuals.
- Mountain Mines, Inc. acquired 88 claims (Lucky Strike and Bumabag Groups) through agreements and deeds of sale.
Exploration and Development
- From 1936-1937, both Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc. engaged mining engineers to explore and develop the area. Mountain Mines, Inc. spent P142,219.00 on pre-war exploration and increased its capital to P1,000,000.00 in 1937.
Post-War Reconstitution
- In 1949-1950, both companies reconstituted their corporate records with the Securities and Exchange Commission.
- In 1953, they filed reconstitution proceedings under Republic Act No. 739 to reconstitute the records of the 170 mining claims. The Bureau of Mines conducted hearings, published notices, and heard testimonies confirming the sales to the companies.
- On May 23, 1956, the Bureau of Mines issued orders reconstituting 88 claims for Mountain Mines, Inc. and 82 claims for Balatoc-Lubuagan Mines, Inc.
Operating Agreements and Exploration
- On July 26, 1956, both companies entered into a royalty-based operating agreement with Benguet Consolidated, Inc. over the 170 claims.
- Various companies, including Mitsubishi and Lepanto Consolidated Mining Corporation, explored the area from 1958 to 1969.
Assessment Works and Tax Payments
- From 1965 to 1967, both companies filed affidavits of annual assessment works and paid real estate taxes for the 170 claims.
- In 1968, Mountain Mines, Inc. and Balatoc-Lubuagan Mines, Inc. filed lease applications and survey orders for specific claims.
Biak-Na-Bato Mining Company's Claims
- In 1967, Bernardo Ardiente, Emilio Peralta, Mario Villarica, Anastasio Canao, and Salvador Ellone located several claims in the same area.
- On February 8, 1969, Biak-Na-Bato Mining Company was formed as a partnership, and the locators transferred their mining rights to the company.
- On December 4, 1969, Biak-Na-Bato Mining Company filed an application for lease and a petition for a lease survey but was denied due to conflicts with the claims of Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc.
Protests and Ocular Inspections
- On January 12, 1970, Biak-Na-Bato Mining Company filed protests against Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc., contesting their rights to certain claims and alleging abandonment.
- The Bureau of Mines conducted ocular inspections in May 1970 and found significant improvements and assessment works by Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc., valued at P582,996.60.
Director of Mines' Decision
- On December 17, 1970, the Director of Mines ruled in favor of Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc., holding that they had a better right to the 170 mining claims.
Appeal to the Secretary of Agriculture and Natural Resources
- Biak-Na-Bato Mining Company appealed to the Secretary of Agriculture and Natural Resources, who ordered a second ocular inspection. The second inspection confirmed the findings of the first.
- On September 17, 1971, the Secretary affirmed the Director of Mines' decision, declaring Biak-Na-Bato Mining Company's claims null and void.
Issue:
- Whether Biak-Na-Bato Mining Company's mining claims were valid or mere "table locations."
- Whether Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc. had abandoned their mining claims.
- Whether the reconstitution proceedings and documents presented by Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc. were fraudulent.
Ruling:
The Supreme Court dismissed the petition and affirmed the decision of the Secretary of Agriculture and Natural Resources. The Court held:
- Biak-Na-Bato Mining Company's claims were mere "table locations" and not valid under the Mining Law.
- Balatoc-Lubuagan Mines, Inc. and Mountain Mines, Inc. did not abandon their claims, as evidenced by their annual assessment works and tax payments.
- The reconstitution proceedings and documents were valid, and the irregularities alleged by Biak-Na-Bato Mining Company did not render them fraudulent.
Ratio:
- (Unlock)