G.R. No. L-21230 - Gold Star Mining Co., Inc. vs. Secretary of Agriculture and Natural Resources

Petitioner: Gold Star Mining Co., Inc., a duly organized domestic corporation engaged in the exploration, exploitation, and utilization of natural resources.
Respondents: The Secretary of Agriculture and Natural Resources, the Director of Mines, and intervenors Anifelina S. Galang, Belen S. Galang, Arsenio Galang, Jr., and Ruperto S. Galang, who had an interest in seven of the twenty-one mining claims.

Gold Star Mining Co., Inc. filed Lode Lease Application No. R-56 with the Bureau of Mines for mining claims denominated as "Isao Nos. 1 to 21" located at Sitio Isao, Barrio Batangsapa, Municipality of Mogpog, Province of Marinduque.
On September 9, 1960, the Director of the Bureau of Mines denied the application on the ground that the petitioner failed to comply with the basic requirements of the Mining Act, as amended, and pertinent mining rules and regulations.

After the denial and an unsuccessful motion for reconsideration (filed on December 19, 1960 by the Director of Mines), the petitioner took the case to the Secretary of Agriculture and Natural Resources.
Intervenors were admitted on motion due to their interest over seven mining claims implicated in the case.
On June 7, 1961, the Secretary of Agriculture and Natural Resources dismissed the petitioner's appeal, holding that the petitioner had failed:

The petitioner received notice of this decision on July 20, 1961, and its subsequent motion for reconsideration was denied on September 17, 1961.

On October 12, 1961, the petitioner filed a verified petition with the Court of First Instance of Marinduque, alleging grave abuse of discretion by the respondents in denying its application, which it claimed caused irreparable damages.
Respondents and intervenors filed a joint answer and raised special defenses, alleging:

The petition was fatally defective in that it failed to allege jurisdictional matters;
It did not state a sufficient cause of action; and
The findings of fact by the administrative bodies were final and conclusive, making them not reviewable by the courts.

The petitioner failed to file its appeal bond within the reglementary period;
The allegation that respondents acted with grave abuse of discretion made the case one for certiorari as a special civil action, which would be beyond the territorial jurisdiction of the Court of First Instance of Marinduque since the respondents had offices in Manila and Quezon City.

The lower court, on February 21, 1963, dismissed the petitioner’s petition on the ground of non-filing of an appeal bond, and held that even if the case were considered a special civil action for certiorari, it would be beyond its jurisdiction.

The petitioner contended that neither the Mining Act nor the Rules of Court explicitly require the filing of an appeal bond in cases of appeal stemming from the decision of the Secretary of Agriculture and Natural Resources.
It further argued that, if Rule 40 of the Rules of Court (mandating an appeal bond) were applicable, its deposit of P32.00 as a filing fee satisfied the requirement.

Despite assertions regarding "grave abuse of discretion," the petition was, by its nature, an appeal from an administrative decision – not an original civil action for certiorari.
Pursuant to Section 4, Republic Act No. 739, an appeal from the decision of the Secretary is appropriately taken to a court of competent jurisdiction, typically a Court of First Instance.

Whether the petitioner’s filing constituted an appeal rather than an original action for certiorari, thereby mandating compliance with the appeal requirements including the filing of an appeal bond.
Whether the petitioner’s argument that its deposit of P32.00 as a filing fee satisfied the requirement for an appeal bond negates the need for an additional bond.
Whether the jurisdictional challenge, based on the presence of respondents’ offices in Manila and Quezon City, affected the lower court’s power to entertain the appeal.