Case Summary (G.R. No. 229413)
Factual Background and Procedural History
Minimax secured MPSA No. 134-99-XIII with the government on May 26, 1999, enabling mining operations within a designated contract area. On June 20, 2014, Minimax granted Agata an Operating Agreement to explore and operate mining activities, with subsequent approvals by the Mines and Geosciences Bureau (MGB) and DENR authorities. Agata sought to purchase the property from the respondents, who refused. Thereafter, Agata filed an expropriation complaint before the Regional Trial Court (RTC) for the property’s acquisition and requested a writ of possession. The RTC granted the writ on June 26, 2015, but the respondents contested it, leading to an appeal before the Court of Appeals (CA), which nullified the writ and ruled that Agata, as a private entity, lacked authority to exercise eminent domain.
Issue Presented
The principal issue is whether Agata Mining Ventures, Inc., as a private entity and transferee of mining rights under the MPSA and Operating Agreement, has the authority to initiate expropriation proceeding and exercise the power of eminent domain over the subject property.
Legal Principles: Eminent Domain and Delegation
Eminent domain is an inherent power of the State to appropriate private property for public use upon payment of just compensation, deeply rooted in constitutional law. The power primarily resides with the legislature but may be delegated to local government units (LGUs) or other public entities, subject to legal controls and limitations. Private entities generally cannot exercise eminent domain unless authorized by law.
Jurisprudential Development on Mining Operators’ Authority
The Court reaffirmed precedent from Didipio Earth-Savers' Multi-Purpose Association, Inc. v. Gozun that qualified mining operators have authority to exercise eminent domain in connection to their mining operations. This authority is derived from successive mining laws starting with Commonwealth Act No. 137 (1936), followed by Presidential Decrees No. 463 and 512, and continuing under the current Philippine Mining Act of 1995 (RA 7942), which collectively recognize mining operations as public use and allow entry, occupation, and use of private lands for mining infrastructure, subject to just compensation.
Statutory Interpretation: Sections 75, 76 of RA 7942 and Historical Context
Section 75 grants easement rights to mining contractors to construct necessary infrastructure, while Section 76 mandates that holders of mining rights shall not be prevented entry into private lands when conducting operations, contingent on notification and compensation for damages. Although Section 76 does not explicitly provide for eminent domain, earlier statutes such as PD 512 expressly authorized surface rights acquisition and eminent domain by mining operators. The Court applied the doctrine against implied repeal, holding these provisions as harmoniously reinforcing the authority to exercise eminent domain.
Transfer and Assignment of Mining Rights and Its Effect on Eminent Domain Power
Under RA 7942, exploration permits and other mining rights may be transferred or assigned to qualified persons subject to government approval. The transferee assumes the rights of the original permittee, including rights to enter, occupy, and conduct mining operations. As Agata is the approved transferee under the Operating Agreement, it inherits Minimax’s rights, including the authority to file expropriation proceedings to acquire necessary land.
Holding on Agata's Authority to Expropriate
The Court held that Agata, as the transferee of Minimax’s mining rights, is legally empowered to file a complaint for expropriation of the subject property. This power springs from the statutory grant under RA 7942 and related mining laws granting eminent domain authority to qualified mining operators and their successors-in-interest.
Clarification on the Scope of Judicial Determination on Operating Agreement Validity
The Court emphasized that the decision does not yet resolve the ultimate val
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Case Syllabus (G.R. No. 229413)
Background and Procedural History
- The respondents are registered owners of a 14.22-hectare parcel of land situated at Payong Payong, Tiningbasan, Tubay, Agusan del Norte.
- Minimax Mineral Exploration Corporation (Minimax) entered into a Mineral Production Sharing Agreement (MPSA No. 134-99-XIII) with the Philippine government on May 26, 1999.
- Minimax subsequently executed an Operating Agreement on June 20, 2014, with Agata Mining Ventures, Inc. (petitioner), granting the latter the exclusive right to explore, develop, and operate the mining area which includes the respondents' property.
- The Operating Agreement was duly registered and approved by the Mines and Geosciences Bureau (MGB) and the Department of Environment and Natural Resources (DENR) Secretary.
- Petitioner offered to purchase the respondents’ land at P175,000 per hectare; the offer was refused.
- Petitioner filed a civil case for expropriation with prayer for writ of possession before the Regional Trial Court (RTC) of Cabadbaran City.
- RTC granted the writ of possession on June 26, 2015, allowing petitioner to enter the property.
- Respondents sought reconsideration before the RTC, which was denied.
- Respondents filed a petition for certiorari before the Court of Appeals (CA) which reversed the RTC decision, nullifying the writ of possession on the ground that petitioner, a private entity, had no authority to exercise eminent domain.
- Petitioner moved for reconsideration before the CA, which was also denied, prompting the present Petition for Review on Certiorari before the Supreme Court.
Issue Presented
- Whether Agata Mining Ventures, Inc., as the transferee of mining rights from Minimax, has the legal authority to file a complaint for expropriation of the subject property under the exercise of the power of eminent domain.
Petitioner’s Arguments
- The trial court's authority to issue a writ of possession is limited to the sufficiency of the complaint and the compliance with the provisional deposit requirements under Section 2, Rule 67 of the Rules of Court.
- Section 76 of Republic Act (R.A.) No. 7942 (Philippine Mining Act of 1995) authorizes qualified mining operators to exercise eminent domain for their mining operations.
- The Mineral Production Sharing Agreement allows Minimax to transfer and assign mining rights to petitioner subject to government approval.
- By virtue of being the assignee with government approval, petitioner is entitled to exercise such eminent domain rights.
Supreme Court’s Ruling Summary
I. Nature of Eminent Domain and its Delegability
- Eminent domain is an inherent power of the State to expropriate private property for public use upon just compensation.
- The power is primarily lodged in the legislature but can be validly delegated to local government units, public entities, or public utilities.
- Such delegation is subject to legislative control, limitations, and must