Case Digest (G.R. No. 151912)
Facts:
In Mario Joel T. Reyes v. People of the Philippines (863 Phil. 611; 116 O.G. 51, December 21, 2020; G.R. No. 237172), petitioner Mario Joel T. Reyes, then Governor of Palawan, approved on April 6, 2006 the renewal of Small Scale Mining Permit (SSMP) No. 37-1 in favor of Olympic Mines and Development Corporation despite clear evidence that Olympic had already extracted the full 50,000 dry metric tons (DMT) of laterite ore authorized under SSMP No. 37 (valid November 4, 2004–November 3, 2006) and the combined 100,000 DMT limit set by their Environmental Compliance Certificates (ECCs) issued October 22, 2004. Olympic’s concessionaire, Platinum Group Metal Corporation, likewise exceeded its separate 50,000 DMT permit. The Provincial Mining Regulatory Board (PMRB), headed by Andronico Baguyo, recommended the renewal without noting the over-extraction. DENR Secretary Angelo Reyes later canceled the ECCs on September 25, 2006 for over-extraction, but the Office of the President reinstaCase Digest (G.R. No. 151912)
Facts:
- Parties and Context
- Mario Joel T. Reyes served as Governor of Palawan, vested with authority to approve small scale mining permits under the Local Government Code and DENR rules.
- Olympic Mines and Development Corporation (OMDC) and Platinum Group Metal Corporation (PGMC) entered into agreements and separately applied for small scale mining permits (SSMP) in Palawan.
- Initial Permits and Extraction Limits
- On November 4, 2004, Reyes issued OMDC SSMP PLW No. 37 (valid to November 3, 2006) allowing 50,000 dry metric tons (DMT) of ore per year; PGMC received SSMP PLW No. 39 with the same terms.
- On October 22, 2004, DENR granted Environmental Compliance Certificates (ECCs) imposing annual extraction limits of 50,000 DMT each.
- Over‐Extraction and Renewal Application
- From May 30, 2005 to April 3, 2006, PGMC transported a total of 203,399.135 DMT on behalf of both companies, exceeding the combined 100,000 DMT limit.
- On March 10, 2006, OMDC applied to renew SSMP PLW No. 37 despite having exhausted its quota; the Provincial Mining Regulatory Board (PMRB) recommended approval.
- On April 6, 2006, Reyes issued SSMP PLW No. 37.1 (valid to April 5, 2008) allowing another 50,000 DMT per year. PGMC transported 79,330 DMT under the renewed permits.
- On September 25, 2006, DENR cancelled OMDC’s ECC for over‐extraction; this cancellation was later reversed by the Office of the President.
- Criminal Charges and Proceedings
- Reyes and PMRB Head Andronico Baguyo were charged with violation of Section 3(e) of RA 3019 (Anti‐Graft and Corrupt Practices Act) for granting unwarranted benefit (renewal of permit despite violations).
- Upon trial, the Sandiganbayan acquitted Baguyo but convicted Reyes for gross inexcusable negligence, sentencing him to 6 years and 1 month to 8 years imprisonment with perpetual disqualification from public office.
- Reyes was initially granted bail at ₱60,000 but the Sandiganbayan revoked it—citing prior bail violations, escape to Thailand, and flight risk.
- Reyes filed a Petition for Review on Certiorari with the Supreme Court, assailing both his conviction and bail revocation.
Issues:
- Did the Sandiganbayan err in convicting Governor Reyes of violating Section 3(e) of RA 3019 by approving the renewal of OMDC’s small scale mining permit despite over‐extraction?
- Did the Sandiganbayan abuse its discretion in revoking Reyes’s bail after conviction on the grounds of bail condition violations and flight risk?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)