Case Digest (G.R. No. 189792) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines, represented by the Department of Environment and Natural Resources (DENR) under Minister Ernesto R. Maceda, together with former government officials Catalino Macaraig, Fulgencio S. Factoran, Angel C. Alcala, Ben Malayang, Roberto Pagdanganan, Mariano Z. Valera, and Romulo San Juan (collectively “petitioners”), vs. Rosemoor Mining and Development Corporation, Pedro Del Concha, Alejandro De la Concha, and Rufo De Guzman (collectively “respondents”). On August 3, 1982, the Bureau of Mines issued Quarry License/Permit (QLP) No. 33 to Rosemoor, covering 330.3062 hectares of high-quality marble deposits in Mount Mabio, part of Biak-na-Bato mountain range, San Miguel, Bulacan. In September 1986, Minister Maceda, citing Section 69 of Presidential Decree No. 463, cancelled License No. 33 by letter and urged reversion of the excluded land to Biak-na-Bato National Park via Proclamation No. 84 (March 9, 1987). Respondents secured preliminary injunctions (Feb Case Digest (G.R. No. 189792) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and grant of license
- Four individuals (Dr. Lourdes S. Pascual, Dr. Pedro De la Concha, Alejandro De La Concha, Rufo De Guzman) prospected high-quality marble in Mount Mabio, Biak-na-Bato, Bulacan and incurred substantial expenses.
- After complying with conditions, the Bureau of Mines (now MGB) issued Quarry License Permit (QLP) No. 33 on August 3, 1982, in favor of Rosemoor Mining and Development Corporation covering 330.3062 hectares.
- Cancellation and preliminary injunction
- On September 6, 1986, DENR Minister Ernesto R. Maceda notified Rosemoor of the cancellation of QLP No. 33 for violation of Section 69, PD 463 (max 100 ha per province) and on public-interest grounds, later confirmed by Proclamation No. 84.
- Petitioners secured a preliminary injunction (February 28, 1992) after filing a P1,000,000 bond; the RTC on September 27, 1996 set aside the cancellation as unconstitutional deprivation without due process and ex post facto.
- Appeals
- The Court of Appeals (CA-GR SP No. 46878) affirmed the RTC decision in toto, ruling the license a property right protected under due process and non-impairment clauses.
- This Supreme Court Petition for Review under Rule 45 challenges (a) issuance of QLP No. 33 in violation of PD 463 § 69 and (b) validity of Proclamation No. 84 as an ex post facto or impairing contract.
Issues:
- Whether QLP No. 33 was issued in blatant contravention of Section 69, PD 463 (limiting quarry licenses to 100 ha per province), rendering it void ab initio.
- Whether Proclamation No. 84, which declared QLP No. 33 a patent nullity and restored the land to Biak-na-Bato National Park, is valid, and whether the constitutional prohibition against ex post facto laws or non-impairment of contracts applies.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)