Case Digest (G.R. No. 226176) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Commission on Indigenous Peoples (NCIP), Zenaida Brigida Hamada-Pawid, Dionesia O. Banua, Conchita C. Calzado, Percy Brawner, Cosme Lambayon, Santos Unsad, and Basilio Wandag (collectively, petitioners) versus Macroasia Corporation (respondent), petitioner NCIP sought to reverse the Court of Appeals’ Amended Decision of March 14, 2016 and Resolution of August 9, 2016, which had denied NCIP’s motion for reconsideration and affirmed a CA Decision of April 22, 2015 ordering NCIP to issue a Certification Precondition for respondent’s mining permit under MPSA No. 220-2005-IVB covering 1,114 hectares in Brooke’s Point, Palawan. The mine application had undergone a Field-Based Investigation and Free and Prior Informed Consent (FPIC) process in 2006 for three directly affected barangays, resulting in a Joint Resolution of Consent on April 21, 2010. An NCIP Regional Review Team and Validation Team likewise recommended issuance of the Certification Precondition, but the NCIP E Case Digest (G.R. No. 226176) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and procedural history
- Petitioners: National Commission on Indigenous Peoples (NCIP), Zenaida Brigida Hamada-Pawid, Dionesia O. Banua, Conchita C. Calzado, Percy Brawner, Cosme Lambayon, Santos Unsad, and Basilio Wandag.
- Respondent: Macroasia Corporation (stylized “MacroAsia” in some parts of the rollo).
- Originating case: CA-G.R. SP No. 124632 before the Court of Appeals, where Macroasia sought issuance of a Certification Precondition pursuant to MPSA No. 220-2005-IVB.
- CA rulings:
- Decision dated April 22, 2015 (granting certification).
- Amended Decision dated March 14, 2016 (directing NCIP to issue Certification Precondition).
- Resolution dated August 9, 2016 (denying NCIP’s motion for reconsideration).
- Petition for Review on Certiorari filed under Rule 45 before the Supreme Court, docketed G.R. No. 226176, seeking reversal of the CA’s Amended Decision and reinstatement of the CA’s April 22, 2015 Decision.
- Pre-litigation and FPIC process
- Issuance of MPSA No. 220-2005-IVB to Macroasia Corporation in December 2005, conversion of old mining leases.
- Conduct of mining exploration and application for development permits, endorsement to NCIP for Free, Prior and Informed Consent (FPIC) and Field-Based Investigation (FBI).
- NCIP Certificate of Compliance dated March 17, 2006; subsequent directives by NCIP Regional Office in March 2010 to conduct FPIC among Pala’wan ICCs/IPs of directly affected barangays Ipilan, Mambalot, and Maasin.
- April 21, 2010 FPIC outcome: Joint Resolution of Consent by ICC/IP leaders and execution of a Memorandum of Agreement/Kalatas ng Kasunduan; recommendation and validation by NCIP Regional and National bodies.
- NCIP En Banc Resolution No. 001–2012 denying Certification Precondition for lack of separate FBI for indirectly affected barangays Aribungos and Barong-barong; denial of reconsideration on February 23, 2012.
- Assignment and renewed FPIC
- Assignment by Macroasia Corporation to Macroasia Mining Corporation of rights and obligations under MPSA No. 220-2005-IVB on June 7, 2019; DENR approval on February 1, 2021.
- Macroasia Mining’s conduct of FPIC and FBI for indirectly affected barangays in August 2022; execution of another Memorandum of Agreement/Kalatas ng Kasunduan; issuance of Pinagkaisang Pahayag dated November 12, 2022 reaffirming consent.
- Compromise Agreement and joint motion
- Joint Motion to Render Judgment Based on Compromise Agreement filed February 21, 2023, with Compromise Agreement dated February 1, 2023.
- Office of the Solicitor General’s Manifestation and Motion dated March 30, 2023 joining the compromise on behalf of NCIP.
- Major recitals of the Compromise Agreement: acknowledgment of proper FPIC/FBI, validation by NCIP offices, consent resolutions of directly and indirectly affected ICCs/IPs, social responsibility initiatives.
- Obligations: Macroasia Mining to secure permits; NCIP to review processes and issue recommendations; parties to file joint motion for dismissal with prejudice; enjoin performance of acts delaying settlement.
- Prayer: Dismiss G.R. No. 226176 with prejudice, declare case closed and terminated based on the Compromise Agreement.
Issues:
- Whether the Compromise Agreement was validly executed and not contrary to law, morals, good customs, public policy, or public order.
- Whether the Supreme Court may render judgment based on the Compromise Agreement and dismiss the petition with prejudice, thereby terminating the case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)