Title
Supreme Court
Calanza vs. Paper Industries Corp. of the Philippines
Case
G.R. No. 146622
Decision Date
Apr 24, 2009
Petitioners' small-scale mining permits, issued by Davao Oriental governor, were void as the area fell under Surigao del Sur and within PICOP's logging concession. RTC lacked jurisdiction; SC upheld CA, ruling permits invalid and boundary disputes must be resolved by provincial sanggunians.

Case Summary (G.R. No. 146622)

Case Overview

The case concerns the denial of entry for the petitioners into what they claimed were their permitted mining sites, which were allegedly within a logging concession area operated by PICOP. The petitioners had applied for small-scale mining permits from the Department of Environment and Natural Resources (DENR), which were later approved by the governor of Davao Oriental, Rosalind Y. Lopez. PICOP contested the legitimacy of these permits, asserting that they were issued improperly and therefore invalid.

Jurisdictional Claims

In their filing, the petitioners sought an injunction against PICOP’s refusal to allow them access to the mining site. PICOP countered by claiming that the Regional Trial Court (RTC) lacked jurisdiction over the matter, given that the area in dispute was situated in Surigao del Sur. It maintained that the issuance of mining permits was invalid under Republic Act No. 7076, which restricts mining in areas covered by timber licenses unless explicitly withdrawn by competent authority.

Trial Court Decision

On November 26, 1993, the RTC ruled in favor of the petitioners, declaring that their mining areas were indeed within Davao Oriental—contrary to PICOP’s claims. The RTC concluded that the governor had the authority to issue mining permits under the Local Government Code of 1991, thereby granting the petitioners the rights to extract gold from the specified areas.

Court of Appeals Reversal

The Court of Appeals, in its decision dated June 19, 2000, reversed the RTC ruling, stating that the RTC had overstepped its bounds by resolving the boundary dispute, which should have been managed by the provincial councils according to the Local Government Code. Furthermore, the appellate court held that the governor had no authority to issue mining permits as that power resided with the Provincial Mining Regulatory Board.

Legal Framework

The case primarily engaged with the Local Government Code of 1991, particularly its provisions addressing boundary disputes and the authority granted to local government units. Section 118 delineates the responsibility for settling such disputes, while Section 119 empowers dissatisfied parties to appeal to the RTC.

Jurisdictions and Permits

The nature of the permits obtained by the petitioners was also called into question. Under both Presidential Decree No. 1899 and Republic Act No. 7076, the proper

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.