Case Summary (G.R. No. 212815)
Petitioners
Republic of the Philippines, represented by the Department of Environment and Natural Resources under Minister Ernesto R. Maceda and former officials in their official capacities
Respondents
Rosemoor Mining and Development Corporation; Pedro Del Concha; Alejandro and Rufo de Guzman
Key Dates
• August 3, 1982 – Issuance of Quarry License (QLP No. 33)
• September 6, 1986 – Cancellation letter by Minister Maceda
• March 9, 1987 – Proclamation No. 84 declared license a nullity
• February 2, 1987 – Effectivity of the 1987 Constitution
• March 30, 2004 – Supreme Court decision
Applicable Law
• Presidential Decree No. 463 (1974 Mineral Resources Development Decree)
• 1987 Philippine Constitution, Article XII, Section 2 (full State control and supervision of natural resources)
• Republic Act No. 7942 (Philippine Mining Act of 1995)
• Proclamation No. 2204 (granting license)
• Proclamation No. 84 (reverting land to national park)
Factual Background
Four individuals discovered high-quality marble on Mount Mabio and, through Rosemoor Mining and Development Corp., secured QLP No. 33 for 330.3062 hectares under PD 463 and Proclamation No. 2204.
Trial Court Decision
The RTC held the quarry license had ripened into a protected property right, invalidated its cancellation without notice and hearing, declared Proclamation No. 84 an ex post facto law, and issued permanent injunctive relief.
Court of Appeals Ruling
The CA affirmed the RTC in toto, recognizing due process and non-impairment protections for the license, and addressed area limits under PD 463 and RA 7942.
Issues Presented
- Whether QLP No. 33 violated Section 69 of PD 463’s 100-hectare limit per province and is void ab initio.
- Whether Proclamation No. 84 is valid or constitutes an ex post facto law, bill of attainder, or violates the non-impairment clause.
Validity of License under PD 463
Section 69 mandates a maximum of 100 hectares per province for any quarry license. QLP No. 33 covered 330.3062 hectares without statutory exception. The clear, mandatory language cannot be bypassed by multiple applications.
Applicability of the 1987 Constitution and RA 7942
The 1987 Constitution’s full State control policy (Art. XII, Sec. 2) applies prospectively, and RA 7942 preserves only valid, pre-existing mining rights. A license void at issuance cannot be “existing” under RA 7942’s Sections 112 and 113.
Voidness of the License
A license granted in violation of a mandatory statutory provision is void ab initio. QLP No. 33’s over-area allocation renders it legally nonexistent and unprotected by due process or non-impairment clauses.
Nature of Quarry Licenses and Police Power
Quarry licenses are privileges subject to the State’s police power. They do not confer irrevocable property or contractual rights; the State may revoke them in the public interest without violating due process or non-impairment protections.
Validity of Proclamation No. 84
Proclamation No. 84, issued under the President’s prerogative and justified by public inter
...continue readingCase Syllabus (G.R. No. 212815)
Parties
- Petitioners: Republic of the Philippines, represented by DENR under Minister Ernesto R. Maceda, and several former government officials
- Respondents: Rosemoor Mining and Development Corporation; Pedro Del Concha; Alejandro and Rufo De Guzman
- Court of origin: Regional Trial Court (RTC) of Bulacan, Trial Branch; appealed to the Court of Appeals (CA); elevated to the Supreme Court under Rule 45
Facts
- Four private individuals obtained government permission to prospect for marble in Biak-na-Bato, San Miguel, Bulacan
- Discovery of high-quality marble deposits in Mount Mabio after extensive prospecting efforts and expenses
- Petitioners secured Quarry License/Permit (QLP) No. 33 covering 330.3062 hectares, valid for 25 years, subject to PD 463 and implementing rules
- Minister Maceda canceled QLP No. 33 by letter dated September 6, 1986, citing violation of Section 69, PD 463, and lack of public interest
- Petitioners filed an amended petition for annulment of cancellation and obtained preliminary injunctions upon bond of ₱1 million
- RTC ruled the cancellation void, declared license a protected property right, granted injunctive relief, set aside bond, allowed damage evidence
- CA affirmed the RTC decision in toto; petitioners’ motion for reconsideration was denied
Trial Court Decision
- Cancellation of QLP No. 33 deemed without jur