Case Summary (G.R. No. 108451)
Applicable Law and Procedural Background
The issues at hand are governed by the 1987 Philippine Constitution and relevant statutory laws concerning property rights and mining permits. The case arises from a petition for review on certiorari against a decision by the Court of Appeals affirming the trial court's denial of a writ of preliminary injunction that would prevent Evelyn Vergel De Dios from mining operations on the property in question.
Acquisition and Subsequent Developments
Solid Homes, Inc. acquired the property from Santiago V. Papa through a Deed of Exchange executed on February 28, 1980. Following the exchange, Santiago Papa was issued Quarry Permit No. 103 by the Bureau of Mines and Geo-Sciences on March 20, 1980, valid for five years but was not renewed post-expiration. On June 16, 1989, Evelyn Vergel De Dios applied for a Small Scale Mining Permit for the same property, which was granted in July 1989.
Conflict Over Mining Rights
Santiago Papa raised concerns with local authorities regarding the issuance of the mining permit to Vergel De Dios. Solid Homes, Inc. attempted to assert its proprietary rights by submitting documentation to the Bureau of Mines and Geo-Sciences, asserting that it possessed prior rights over the property. However, Solid Homes' protests were dismissed, leading them to file a complaint for quieting of title in the Regional Trial Court of Bulacan, seeking judicial intervention against Vergel De Dios's mining activities on their property.
Trial Court Proceedings and Decisions
The trial court initially issued a temporary restraining order but subsequently denied the application for a writ of preliminary injunction due to lack of jurisdiction, invoking Presidential Decree No. 605, which restricts courts from issuing injunctions or restraining orders in cases involving natural resource exploitation permits. Solid Homes, Inc. then appealed the trial court's decision to the Court of Appeals, alleging grave abuse of discretion.
Court of Appeals’ Findings
The Court of Appeals upheld the trial court's ruling, noting that Solid Homes' actions constituted forum-shopping, as it had simultaneously pursued remedies through both the regional trial court and the Department of Environment and Natural Resources (DENR). The appellate court highlighted that the issues in both proceedings were fundamentally the same, namely, the determination of legal rights over mining permits concerning the same property.
Supreme Court’s Ruling on Forum-Shopping
The Supreme Court affirmed the findings of the Court of Appeals, emphasizing that pursuing parallel actions i
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Case Overview
- This case is a petition for review on certiorari seeking to annul the decision of the Court of Appeals dated September 30, 1992.
- The case pertains to the application for a writ of preliminary injunction filed by Solid Homes, Inc. against private respondent Evelyn Vergel De Dios, which was denied by the Regional Trial Court in Bulacan.
- The property in question is located at Barangay Banaban, Angat, Bulacan, identified as Lot No. 3863 and covered by Transfer Certificate of Title No. T-130829, registered in the name of Santiago V. Papa.
Factual Background
- Solid Homes, Inc. acquired the property through a Deed of Exchange dated February 28, 1980, executed with Santiago Papa.
- Following this acquisition, Solid Homes also inherited other interests, including a pending application for a quarry permit.
- The Bureau of Mines granted Quarry Permit No. 103 to Santiago Papa for a five-year term on March 20, 1980, which he failed to renew after its expiration.
- On June 16, 1989, Evelyn Vergel De Dios applied for a Small Scale Mining Permit on the same property, which was granted on July 19, 1989.
Administrative Proceedings
- Santiago Papa protested the issuance of the mining permit to Vergel De Dios, which was referred to the DENR.
- Solid Homes submitted documents asserting their priority rights over the property to the Bureau of Mines and Geo-Sciences on November 16, 1989.
- Vergel De Dios applied for a renewal of her mining permit on April 15,