G.R. No. 4852 - People vs. Calimag

On September 2, 1980, the Director of Mines and Geo-Sciences declared the preferential right of June Prill Brett to explore, develop, exploit, and lease the "MAMAKAR" mining claims in Sitio Palasaan, Barrio Suyoc, Municipality of Mankayan, Benguet.
Private respondents (heirs of John and Maria Guilles, among others) appealed the decision to the then Ministry of Natural Resources.

On October 6, 1982, the Minister of Natural Resources dismissed the appeal against the Director’s decision.
The heirs of Guilles later filed an appeal to the Office of the President (MNR Case No. 5096) but failed to properly prosecute it.
On June 25, 1984, Minister Teodoro Pena reversed the October 6, 1982 decision, declaring Brett’s claims null and void ab initio, even after the previous decision had become final and executory.
On July 25, 1984, petitioner Brett sought a reconsideration of the June 25, 1984 decision and also requested a status quo order.

The status quo order was issued on August 20, 1984, directing respondents to answer within five days, but none complied.

With the reconsideration unresolved, on February 19, 1985, Brett filed a petition for certiorari and prohibition before the Supreme Court asking for the nullification of the June 25, 1984 decision and for a preliminary injunction.

The petition for certiorari was referred on February 27, 1985, to the Court of Appeals by the Supreme Court.

On March 7, 1985, the Court of Appeals initially dismissed the petition citing its prematurity as Brett still had an unresolved motion for reconsideration pending in the Ministry.
After additional filings by Brett to inform the court about the denial of her motion for reconsideration, the respondent court on April 10, 1985, reconsidered its earlier dismissal but ultimately ruled against Brett by holding that she had failed to exhaust administrative remedies.

The Court relied on Section 50 of Presidential Decree No. 463 and also cited PD No. 605 restricting courts from issuing preliminary injunctions in cases involving administrative acts on public grants.

On March 24, 1986, after filing the petition in G.R. No. 74223, James Brett sent a letter to the newly appointed Minister Ernesto Maceda requesting that the June 25, 1984 decision be rectified.
In response, on June 10, 1986, Minister Maceda set aside Minister Pena’s June 25, 1984 decision and reinstated the original decisions of the Director and of Minister Pena dated October 6, 1982.
Brett then filed a petition before the Court of Appeals on June 23, 1986 (CA-G.R. SP No. 09349), seeking to enjoin the enforcement of Minister Maceda’s order and to declare it null and void on grounds of lack of jurisdiction.
An appeal was also made to the Office of the President (O.P. Case No. 3360), and the Office ordered the necessary administrative steps.
The Court of Appeals on October 24, 1986, in addressing CA-G.R. SP No. 09349, dismissed the petition noting that a similar pending appeal existed in the Office of the President and citing Section 17 of the Interim Rules of Court barring duplicative petitions.

Whether the Court of Appeals erred in dismissing Brett’s original action for certiorari on the ground of non-exhaustion of administrative remedies.
Whether the invocation of Presidential Decree No. 605 by the Court of Appeals to deny the issuance of a writ of preliminary injunction was proper, given that the decree might be seen as not displacing the inherent judicial authority to grant injunctions.

Whether the dismissal of the petition for certiorari by the Court of Appeals, on the basis that a pending appeal existed both before the Office of the President and with the Supreme Court, was proper.
Whether the simple, unsworn, and unsubscribed letter submitted by the heirs to the President should be considered a valid exercise of their right to seek redress, or if it fell short as a formal administrative remedy.