G.R. No. L-27849 - Pio vs. Marcos

Petitioner Mackenzie Pio claimed ownership of a parcel of approximately 400 hectares in Poquis, Municipality of Tuba, Mountain Province, which he alleged to have inherited from his father, Artemio Pio.
Within this land, there were allegedly 48 mining claims located by his father in the early 1930s.
Petitioner initiated legal proceedings in the Court of First Instance of Baguio City on April 23, 1965, seeking recovery of eight specific mining claims (namely: Sheland, Sheland Fr., Minas, Sato, Oking, Ma, Padcal, and Bayengan) and the surface rights of about ten hectares against Philex Mining Corporation.

In the complaint, petitioner asserted that Philex had unlawfully occupied a portion of his land by constructing facilities (mill, crusher, bunkhouses, cottages) and was mining ores (principally gold and copper) from the disputed mining claims.
Petitioner claimed that continued operations would deplete the ore reserves, causing irreparable harm.
He prayed for:

A recovery of possession of the premises.
Monetary relief in the form of monthly rentals for the surface rights and operating mining claims.
Payment of attorney’s fees and costs.

On August 25, 1965, petitioner supplemented his complaint by seeking a writ of preliminary injunction to restrain Philex from continuing its mining operations and related improvements on the disputed claims.

On September 10, 1965, the trial judge deferred the petition for a writ of preliminary injunction pending the presentation of evidence by Philex.
Despite this deferment, on March 15, 1966, the respondent judge issued an order directing the issuance of a writ of preliminary injunction against Philex, subject to the filing of an injunction bond of P50,000.00 by petitioner.
Philex subsequently filed a motion for reconsideration of the March 15 order (filed on April 16, 1966), which was left pending and kept under advisement.

The Nevadas (heirs of Baldomero Nevada, Sr.) asserted a right to operate the mining claims through mining lease contracts executed by the government.
The Heirs of Bonifacio Montilla (and later the Nicolases) claimed an undivided interest in the mining claims and contested the exclusivity of the mining rights claimed by the Nevadas.
Additional intervenors included George T. Scholey (an assignee), the National Mines and Allied Workers Union (employees of Philex), and members of an Igorot cultural group who claimed ancestral rights over the land.

Contentions over the authenticity and chain of title of the mining claims.
Allegations of suppression and tampering with evidentiary documents by petitioner during trial.
Disputes over the proper scope of jurisdiction between the administrative authority (Director of Mines under Republic Act 4388) and the regular judicial courts.

The trial court issued orders (August 19, 1967 and December 20, 1967) directing Philex to deposit all royalties paid to the Nevadas with designated banks pending resolution of the dispute.
Bonds were required from intervenors (e.g., Montillas and Nicolases) to secure their claims.

Subsequent motions for reconsideration were filed by various parties regarding these deposit orders, with the Nevadas and others contesting the jurisdiction and appropriateness of such orders.

Petitioner, frustrated by the respondent judge’s failure to issue the actual writ of preliminary injunction (despite the March 15, 1966 order and the filing of the required bond), sought a writ of mandamus from the Supreme Court.
The mandamus petition aimed to compel the trial court to act in accordance with its earlier directive.
Petitioner argued that the issuance of the injunction was a ministerial act to be executed once his bond was filed, asserting that irreversible harm would ensue from the continued mining.

Whether the issuance of a writ of preliminary injunction is a ministerial duty of the judge or a discretionary act requiring careful evaluation of the merits and pending evidence.
Whether petitioner’s claim of irreparable damage and the accompanying request to enjoin Philex’s mining operations was sufficiently clear and urgent to warrant a mandamus order.

Whether mandamus is available to control the trial court’s exercise of judicial discretion in issuing an injunction, particularly in light of unresolved reconsideration motions.
The extent to which the court may compel the judge to act when substantial evidentiary disputes and pending administrative reconsiderations remain.

Whether the trial court has jurisdiction over disputes arising from conflicting mining claims, given that Republic Act 4388 vested exclusive original jurisdiction over “conflicts and disputes arising out of mining locations” to the Director of Mines.
How the dual nature (judicial vs. administrative) of petitioner’s causes of action is to be delineated:

The first cause (recovery of possession and surface rights) being judicial.
The second cause (disputing Philex’s right to operate the mining claims) alleged to be beyond the court’s jurisdiction.

Whether the orders directing Philex to deposit royalties (and the conditions attached thereto) were within the trial court’s jurisdiction and an appropriate exercise of its discretion.
The impact of these orders on the intervenors’ rights and on the overall resolution of the disputes concerning mining operations and royalty distributions.