G.R. No. 207942 - Yinlu Bicol Mining Corp. vs. Trans-Asia Oil and Energy Development Corp.

The subject comprises 13 mining claims in Barrio Larap, Jose Panganiban, Camarines Norte, originally owned and mined by Philippine Iron Mines, Inc. (PIMI), which ceased operations in 1975 and whose Larap Mines were foreclosed by Manila Banking Corporation (MBC) and Philippine Commercial and Industrial Bank (PCIB/BDO).
In 1976, the Bureau of Mines prepared a Technical Feasibility Study on rehabilitating the PIMI Larap Mines, prompting the Government to open the area for exploration.

From November 1978 to 1982, the Benguet Corporation–Getty Oil Consortium held an Exploration Permit for uranium, then withdrew after four years.
Trans-Asia Oil and Energy Development Corporation began exploration in 1986, entered a 1996 operating agreement with Philex Mining Corporation, and in 1997 applied (amended 1999) for Mineral Production Sharing Agreement (MPSA) No. 252-2007-V, granted on July 28, 2007, covering exclusive mineral rights.

On August 31, 2007, Yinlu Bicol Mining Corporation notified DENR it had acquired PIMI’s pre-1935 mining patents (Patent Nos. 15–18 covering “Busser,” “Superior,” “Bussamer,” and “Rescue” Placer Claims totaling 192 ha) via deed of absolute sale from MBC/BDO, overlapping more than half of Trans-Asia’s MPSA area.
Trans-Asia sought access to carry out exploration; Yinlu refused, prompting referral to DENR Secretary for resolution.

DENR Secretary Atienza framed two issues: (a) whether Yinlu’s patents predated the MPSA, and (b) whether they remained valid and subsisting.
On May 21, 2009, the Secretary held that:

Patents issued to PIMI in 1930 were valid and lawfully transferred to Yinlu.
Failure to register under PD 463 was excused by force majeure (PIMI’s financial losses and foreclosure).
Mining patents under the Philippine Bill of 1902 conferred private ownership of surface and minerals, and the Regalian doctrine applied only after the 1935 Constitution.

The MPSA was ordered amended to excise Yinlu’s patented areas. DENR denied Trans-Asia’s motion for reconsideration on November 27, 2009.

Trans-Asia appealed; on May 4, 2010 OP Case No. 09-L-638 affirmed the DENR decision, holding:

Yinlu’s Torrens titles, traceable to the 1902 Bill, were conclusive and indefeasible under PD 1529.
Patents vested rights exempt from the constitutional prohibition on alienation of natural resources if perfected before November 15, 1935.

OP denied Trans-Asia’s first motion on June 29, 2010, and second motion (deemed unmeritorious) on March 31, 2011, finalizing its ruling.

On October 30, 2012, the CA reversed DENR and OP, ruling Yinlu’s patents lapsed for non-registration under PD 463. The CA denied Yinlu’s motion for reconsideration on June 27, 2013.
Yinlu appealed to the SC. On January 12, 2015, the SC reversed and set aside the CA decision, reinstating the OP decisions and DENR order, and directing exclusion of Yinlu’s patented areas from the MPSA.

Whether Trans-Asia’s petition for review before the CA was timely filed within the 15-day reglementary period under Rule 43, Sec. 4 of the Rules of Court, considering only one motion for reconsideration is allowed.
Whether Yinlu’s mining patents, issued under the Philippine Bill of 1902 and perfected before November 15, 1935, remain valid, subsisting and superior to a subsequent MPSA.
Whether the titles acquired by Yinlu are mining patents or homestead patents.
Whether Yinlu’s absolute sale of its Torrens titles included the minerals in situ.
Whether the CA’s decision violated Yinlu’s constitutional right that private property may not be taken for public use without just compensation.
Whether the principle of laches applies to vested, titled mining property.
Whether Yinlu’s mining patents impaired the State’s share in its natural resources.