G.R. No. 171348 - People vs. Erguiza

A mining corporation duly organized under Philippine laws.
Holder of fifty (50) mining claims located in Jose Panganiban, Camarines Norte.
Claims acquired under the provisions of the Act of the U.S. Congress dated 1 July 1902 (the "Philippine Bill of 1902").

Presidential Decree No. 1214 (issued on 14 October 1977) required holders of subsisting and valid patentable mining claims located under the provisions of the Philippine Bill of 1902 to file a mining lease application within one (1) year from the approval of the Decree.
Petitioner filed its mining lease application on 13 October 1978 "under protest" with a reservation indicating that it was not waiving its rights over its mining claims until the validity of the Decree had been determined by the Court.
On 10 October 1978, three days before filing the mining lease application, petitioner initiated the present special civil action for certiorari and prohibition.
The petition sought:

The Court initially issued a temporary restraining order on 19 October 1978, obliging respondents to comment on the petition, with the TRO set to continue until further order by the Court.

Claims to a vested right over its mining claims, asserting that they were already regarded as its private and exclusive property based on past decisions.
Cites rulings from the Court of First Instance of Camarines Norte in land registration proceedings (including a September 1951 case involving Gervacio Liwanag) and LRC Case No. 240 (filed in 1960 and decided in 1974).
Argues that the Decree amounts to a deprivation of property without due process of law.

Petitioner lacked standing because it had not exhausted all available administrative remedies.
Highlight the pending appeal with the Office of the President concerning the ruling of the DNR Secretary issued on 2 April 1977 in DNR Case No. 4140.
Assert that forty-four (44) of the petitioner's fifty (50) mining claims were found void for lacking valid "tie points" and that all mining claims were declared abandoned and cancelled due to non-compliance under the Philippine Bill of 1902 and Executive Order No. 141.

Petitioner referred to decisions in McDaniel v. Apacible and Gold Creek Mining Corp. v. Rodriguez to support the claim that mining claim location confers a property right.
Respondents pointed to the principle of exhaustion of administrative remedies, notably emphasizing the decision in Ham v. Bachrach Motor Co. Inc.

Whether they were valid, subsisting, and patentable.
Whether they had become abandoned or cancelled due to non-compliance with legal requirements.

The procedural propriety of filing a petition for certiorari and prohibition without fully exhausting administrative remedies.
The legitimacy and constitutionality of Presidential Decree No. 1214 as an exercise of state power over natural resources and the public domain.

Whether petitioner had the necessary standing to file the special civil action without first exhausting all available administrative remedies.
Whether the existence of a pending appeal with the Office of the President precludes the Court from addressing the petition at that time.

Whether petitioner’s mining claims, though located under the Philippine Bill of 1902 and previously recognized in certain land registration proceedings, can be deemed vested property or merely possessory rights.
Whether, even if presumed valid at the time of location, the claims could be forfeited or deemed abandoned for failure to comply with legal requirements.

Whether the Decree, by mandating the filing of mining lease applications and effectively waiving the right to a patent, constitutes a deprivation of property without due process.
Whether the Decree is consistent with the sovereign power of the State over natural resources and the public domain as provided under the relevant constitutional provisions.