Case Summary (G.R. No. 217837)
Facts
On May 3, 2007, Onephil Mineral Resources, Inc. filed an Exploration Permit Application covering a substantial area in Marinduque, which was found to overlap with existing mining claims. Following amendments to its application, Onephil still encountered conflicts with other mining applications, including those held by the Marcopper Mining Corporation. Marcopper, aware of these overlapping claims, sought to protect its mining interests by contacting the respondents to ensure that its areas were closed to further mining applications.
Despite Marcopper’s efforts and communications, Onephil's application proceeded, leading to further contention, resulting in Marcopper filing a Petition for Prohibition and Mandamus against the MGB officials. The Regional Trial Court (RTC) dismissed this petition for lack of jurisdiction, finding it fell under the exclusive jurisdiction of the Panel of Arbitrators established under the Philippine Mining Act.
Applicable Law
The relevant law governing this dispute is Republic Act No. 7942, known as the Philippine Mining Act, which outlines the processes for issuing mining permits and the jurisdiction of disputes in the mining sector.
Judicial Proceedings
The RTC ultimately ruled that the nature of the dispute was fundamentally a mining dispute due to the overlap of mining claims, which necessitated technical expertise for resolution, thus falling under the jurisdiction of the Panel of Arbitrators. The Court of Appeals (CA) affirmed this ruling, clearly defining the case as one that requires specialized knowledge in mining and related matters.
Issues Presented
The petitioners raised several issues for resolution by the Supreme Court, principally arguing that the CA erred in categorizing the dispute as a mining dispute, emphasizing the claims should instead pertain to property rights and the protected status of private lands under the Mining Act. Additionally, they contended that the earlier Supreme Court ruling in the G.R. No. 188229 established jurisdiction in favor of the RTC and not the Panel of Arbitrators.
Court's Analysis and Ruling
The Supreme Court denied the petition, affirming the CA's decision that the Panel of Arbitrators retained exclusive jurisdiction over mining disputes. The Court highlighted that the petitioners could not sidestep the established legal framework by framing their action as one for prohibition and mandamus. The Court’s ruling clarified that the essential questions and relief sought were intrinsically linked to mining rights, which the Panel of Arbitrators is tasked with adjudicating.
Moreover, the Court reiterated that jurisdictional issues may be raised at any stage, and thus, the previ
...continue readingCase Syllabus (G.R. No. 217837)
Case Overview
- This petition for review on certiorari was filed under Rule 45 of the Rules of Court.
- It challenges the Decision dated August 14, 2014, and the Resolution dated April 16, 2015, of the Court of Appeals (CA) in CA-G.R. SP No. 129058.
- The CA dismissed the petitioners' appeal and affirmed the Decision dated December 21, 2011, of the Regional Trial Court (RTC) of Manila, Branch 52, which had dismissed the petitioners' amended petition for prohibition and mandamus.
Background Facts
- On May 3, 2007, Onephil Mineral Resources, Inc. (Onephil) filed an Exploration Permit Application (EPA) covering 5,335.0806 hectares in Marinduque.
- The Mines and Geosciences Bureau (MGB) found that Onephil's application overlapped several existing mining applications and claims.
- Marcopper Mining Corporation (Marcopper), the operator of the San Antonio Copper Project (SACP), had a pending application for a Mineral Production Sharing Agreement (MPSA) covering 763.6650 hectares filed on March 22, 2001.
- Marcopper objected to Onephil's application, asserting that the areas covered by the SACP were closed to mining applications.
- On October 30, 2007, Onephil submitted an amended application, which was found to have no conflict with existing claims, leading to the issuance of an Area Status and Clearance in its favor.
- Despite this, Marcopper sought to expand its MPSA and filed an amended sketch