Title
Itogon-Suyoc Mines, Inc. vs. Office of the President
Case
G.R. No. 111157
Decision Date
Mar 19, 1997
ISMI petitioned to annul OP's decision affirming MNR's dismissal of its mining claim appeal due to late filings and invalid tie points, claims; Supreme Court upheld OP's ruling.
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Case Summary (G.R. No. 111157)

Applicable Law and Appeal Process

  • The governing law for mining claims is Presidential Decree No. 309, which establishes rules for the speedy resolution of conflicting mining claims.
  • Section 5 of P.D. No. 309 allows for an appeal from the Secretary of the Department of Environment and Natural Resources to the President within five days, with the President's decision being final and executory.
  • Petitioner Itogon-Suyoc Mines, Inc. (ISMI) must demonstrate that the Office of the President (OP) acted with grave abuse of discretion or exceeded its jurisdiction in its decisions.

Motion for Reconsideration Timeliness

  • P.D. No. 309 does not specify a period for filing a motion for reconsideration of the President's decision.
  • However, since the law uniformly sets a five-day period for appeals, the Court concludes that a motion for reconsideration should also be filed within five days.
  • ISMI's motion for reconsideration was filed beyond this period, leading to its proper denial by the OP.

Validity of Mining Claims

  • The OP declared ISMI's mining claims null and void based on findings that they were "floating" and lacked proper tie points to fixed natural objects or permanent monuments.
  • Petitioner argued that the requirement for tie points was merely directory; however, this argument was rejected as the law mandates such descriptions for valid mining claims.
  • Act No. 624 reinforces that the description of mining claims must reference permanent monuments, making compliance mandatory.

Purpose of Tie Point Requirement

  • The requirement for a description of mining claims with reference to permanent objects aims to prevent "floating" claims.
  • The law's intent is to ensure clarity and prevent disputes over mining claims, which ISMI's claims failed to meet.

Administrative Findings and Evidence

  • The OP's reliance on the Bureau of Mines' findings, which deemed ISMI's claims null and void, was upheld as there was no grave abuse of discretion.
  • The Bureau's conclusions were supported by substantial evidence, and the OP's decision was consistent with the Bureau's expertise in mining law.

Procedural History and Appeals

  • ISMI's petition for certiorari sought to annul the OP's decisions affirming the Bureau's findings and the Minister of Natural Resources' orders.
  • The OP's decisions were based on the Bureau's findings that ISMI's claims were invalid due to lack of proper documentation and compliance with mining laws.
  • ISMI's appeals were dismissed for failing to meet the required timelines and for not providing sufficient evidence of valid claim transfers.

Assignment and Reconstitution of Claims

  • The Bureau found that ISMI could not prove valid assignments of its mining claims from original locators, as the necessary documentation was either...continue reading

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