G.R. No. 146622 - Calanza vs. Paper Industries Corp. of the Philippines

Petitioners—Leonora P. Calanza, Eva M. Amoren, Gene P. Roao, Sanny C. Calanza, Gregorio C. Yncierto II, and Angel M. Puyo—filed applications for small-scale mining permits on August 23, 1991, with the Mines and Geo-Sciences Development Service of the DENR, Region XI, Davao City.
They indicated that they intended to extract gold from an area purported to be within the Municipality of Boston, Davao Oriental.

On December 22, 1992, Governor Rosalind Y. Lopez of Davao Oriental approved the applications and issued six small-scale mining permits in favor of the petitioners.
The controversy arose because the mining areas applied for by petitioners fell within the logging concession of the respondent Paper Industries Corporation of the Philippines (PICOP) under existing Timber License Agreements (TLAs), covering vast forest lands across several provinces, including Surigao del Sur, Agusan del Sur, Davao Oriental, and Davao del Norte.
Petitioners negotiated with PICOP for access to the mining site at Barangay Catihan, Municipality of Boston, Davao Oriental, which set the stage for dispute.

PICOP, represented by its officer Roberto A. Dormendo, refused the petitioners’ entry into the mining area on the basis that it had the exclusive right of occupation, possession, and control over the concession area.
PICOP argued that the petitioners’ permits were defective because:

They were issued by the governor, who lacked the legal authority to do so, as the mining area was claimed to be situated in Barangay Pagtilaan, Municipality of Lingig, Surigao del Sur.
Under Republic Act No. 7076 (People’s Small-Scale Mining Act of 1991), mining permits cannot be issued over areas under forest rights (such as TLAs or forest reservations) without formal withdrawal of that status by competent authority.

On May 7, 1993, petitioners filed a Complaint for Injunction with a prayer for a restraining order, damages, and attorney’s fees before the Regional Trial Court (RTC) of Banganga, Davao Oriental, Branch 7.
The petitioners sought to enjoin PICOP and its agents from barring their access to the disputed mining areas.
PICOP countered by challenging the jurisdiction of the RTC, asserting that the disputed area was located in Surigao del Sur, and maintained that the permits issued were void ab initio.

The proper territorial jurisdiction was with Davao Oriental, either for Barangay Pagtilaan as claimed by PICOP or Barangay Catihan as claimed by the petitioners.
Under Section 465, paragraph (b), Sub-paragraph (3)iv of Republic Act No. 7160, the governor possessed the power to issue permits.

The RTC decision declared that petitioners had the right to extract gold and enjoined PICOP and its agents from obstructing their access to the mining areas.

PICOP appealed the RTC decision.
On June 19, 2000, the Court of Appeals reversed the RTC’s ruling and dismissed the complaint on two grounds:

The RTC improperly intervened in a boundary dispute between Davao Oriental and Surigao del Sur, a matter reserved for the sangguniang panlalawigans under the Local Government Code.
The governor did not have the statutory authority to issue mining permits under Republic Act No. 7076, as such power is conferred upon the Provincial Mining Regulatory Board.

Republic Act No. 7076, which governs the issuance of small-scale mining permits.
Provisions of the Local Government Code of 1991 (Sections 465 and 118-119) that delineate jurisdiction over boundary disputes between local government units.

Precedents affirming that a court rendering judgment without jurisdiction renders such decisions null and void were also cited.

Whether the mining areas in controversy fall within the territory of Davao Oriental or Surigao del Sur.

Whether the permits issued by the governor of Davao Oriental are valid given that Republic Act No. 7076 vests the issuance of such permits in the Provincial Mining Regulatory Board.

Whether PICOP has the right and authority to deny petitioners access to and prevent them from conducting mining operations in the disputed areas.

Whether the RTC had proper jurisdiction to adjudicate and resolve the boundary dispute between the two provinces given the mandate provided under the Local Government Code and related statutory provisions.