Facts:

The case involves Itogon-Suyoc Mines, Inc. (ISMI) as the petitioner and the Office of the President, Secretary of the Department of Environment and Natural Resources, Director of Mines and Geosciences Bureau, and private respondents James Brett, Edgar Kapawen, Lily Camara, and Jaime Paul B. Panganiban as respondents. The events leading to this case began with ISMI filing separate protests with the Bureau of Mines and Geosciences against the mining claims of the private respondents, alleging that their claims overlapped with ISMI's valid mining claims located in Suyoc, Mankayan, Benguet. The Bureau initially ruled in favor of the private respondents, granting them exclusive rights to their claims while also recognizing ISMI's rights to certain claims. However, ISMI's appeal to the Ministry of Natural Resources (MNR) was dismissed due to procedural issues, including the late filing of its appeal memorandum. After a series of decisions and motions for reconsideration...

Facts:

Background of the Case

• Itogon-Suyoc Mines, Inc. (ISMI) filed a petition for certiorari under Rule 65 of the Rules of Court to annul the decision and resolution of the Office of the President (OP) in O.P. Case No. 1657. The OP had dismissed ISMI's appeal and affirmed the order of the Minister of Natural Resources (now Secretary of the Department of Environment and Natural Resources) dated 15 July 1986.

Mining Claims and Protests

• ISMI filed separate protests with the Bureau of Mines and Geosciences (Bureau) against private respondents James Brett, Edgar Kapawen, and Lily Camara, alleging that their mining claims overlapped ISMI's valid and existing mining claims. Jaime Paul B. Panganiban intervened in the protests.
• ISMI claimed that its mining claims, such as "DAGAS FR.", "NANCY FR.", and others, were overlapped by Brett's "KEDSER I" and "KEDSER II," Kapawen's "EDGAR II," and Camara's "FBJ," among others. All conflicting claims were located in Suyoc, Mankayan, Benguet.

Bureau of Mines Decision

• On 17 February 1984, the Bureau ruled in favor of Brett, Kapawen, and Panganiban, granting them exclusive rights to their mining claims. ISMI was granted rights only to certain claims like "DURAY," "NENA," and others.

Appeal to the Ministry of Natural Resources (MNR)

• ISMI appealed to the MNR, which initially dismissed the appeal for failure to submit the appeal memorandum on time. However, on 13 February 1986, the MNR reversed its decision, declaring Brett, Kapawen, and Panganiban's claims null and void for overlapping ISMI's valid claims.
• On 15 June 1986, the MNR reconsidered and reinstated its original order dismissing ISMI's appeal, citing ISMI's failure to file the appeal memorandum within the five-day reglementary period.

Appeal to the Office of the President (OP)

• ISMI appealed to the OP, which affirmed the MNR's decision on 12 January 1993, upholding the Bureau's ruling. The OP denied ISMI's motion for reconsideration on 15 June 1993, stating that the motion was filed late and that the issues had already been considered.

Issue:

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Ruling:

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Ratio:

1. Timeliness of Motion for Reconsideration: Under Presidential Decree No. 309, the reglementary period for filing a motion for reconsideration is five days. ISMI filed its motion beyond this period, rendering it untimely.
2. Validity of Mining Claims: Section 28 of the Philippine Bill of 1902 requires mining claims to have valid tie points referenced to natural objects or permanent monuments. ISMI's claims lacked these tie points, making them "floating" and invalid.
3. Assignment of Mining Claims: ISMI failed to provide valid deeds of assignment or transfer from the original locators. The affidavits presented were insufficient to prove legal transfer.
4. Reconstitution of Declarations of Location: ISMI's declarations of location were not properly reconstituted under Republic Act No. 739 and Mines Administrative Order No. V-5. The affidavits used for reconstitution were not filed or processed in accordance with the law.
5. Perfection of Appeal: ISMI's appeal to the MNR was not perfected on time, as it failed to file the appeal memorandum within the five-day reglementary period. The law mandates strict compliance with this period in mining cases.

The Court emphasized that administrative decisions, especially those involving mining claims, are entitled to respect unless there is proof of grave abuse of discretion, fraud, or error of law. ISMI failed to demonstrate such abuse or error on the part of the OP.