Case Digest (G.R. No. 175368)
Facts:
- The case involves the League of Provinces of the Philippines as the petitioner against the Department of Environment and Natural Resources (DENR) and Hon. Angelo T. Reyes, Secretary of DENR.
- The petition was filed on April 11, 2013, challenging the constitutionality of certain provisions of the Local Government Code of 1991 and the People's Small-Scale Mining Act of 1991.
- The petitioner sought to declare Section 17(b)(3)(iii) of Republic Act (R.A.) No. 7160 and Section 24 of R.A. No. 7076 unconstitutional.
- The petition aimed to prohibit the respondents from exercising control over provinces and to declare the cancellation of small-scale mining permits issued by the Provincial Governor of Bulacan as illegal.
- The case originated on March 28, 1996, when Golden Falcon Mineral Exploration Corporation applied for a Financial and Technical Assistance Agreement (FTAA) for 61,136 hectares in Bulacan, which was denied on April 29, 1998.
- Golden Falcon's appeal was upheld by the DENR on July 16, 2004, maintaining the denial.
- Other individuals filed applications for quarry permits in the same area, and Atlantic Mines and Trading Corporation applied for an exploration permit on September 13, 2004.
- The DENR Secretary ruled that the area was open for mining applications only after the finality of Golden Falcon's denial on August 11, 2004, declaring the small-scale mining permits issued by the Provincial Governor of Bulacan null and void.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that Section 17(b)(3)(iii) of the Local Government Code of 1991 and Section 24 of the People's Small-Scale Mining Act of 1991 are constitutional.
- The Court held that the DENR Secretary's actions in nullifying the small-scale mining permits ...(Unlock)
Ratio:
- The Supreme Court emphasized the presumption of constitutionality of statutes, stating that a law can only be declared unconstitutional if there is a clear and unequivocal breach of the Constitution.
- The Court found that the provisions in question did not infringe upon local autonomy but established a framework for the supervision and control of mining activities by the DENR, consistent with the const...continue reading
Case Digest (G.R. No. 175368)
Facts:
The case involves the League of Provinces of the Philippines as the petitioner against the Department of Environment and Natural Resources (DENR) and Hon. Angelo T. Reyes, in his capacity as Secretary of DENR, as respondents. The petition was filed on April 11, 2013, concerning the constitutionality of certain provisions of the Local Government Code of 1991 and the People's Small-Scale Mining Act of 1991. The petitioner sought to declare Section 17(b)(3)(iii) of Republic Act (R.A.) No. 7160 and Section 24 of R.A. No. 7076 unconstitutional, to prohibit the respondents from exercising control over provinces, and to declare the cancellation of small-scale mining permits issued by the Provincial Governor of Bulacan as illegal.
The events leading to the case began on March 28, 1996, when Golden Falcon Mineral Exploration Corporation (Golden Falcon) applied for a Financial and Technical Assistance Agreement (FTAA) covering 61,136 hectares in Bulacan. The application was denied on April 29, 1998, due to the lack of area clearances. Golden Falcon appealed this decision, but on July 16, 2004, the DENR's Central Office upheld the denial. Meanwhile, on February 10, 2004, other individuals filed applications for quarry permits covering the same area. Subsequently, Atlantic Mines and Trading Corporation (AMTC) applied for an exploration permit for a portion of the same area on September 13, 2004.
The DENR Secretary later ruled that the area was only open for mining applications after the finality of the denial of Golden Falcon's application on August 11, 2004. The DENR Secretary declared t...