Case Summary (G.R. No. 207942)
Petitioner
Yinlu Bicol Mining Corporation
Respondent
Trans-Asia Oil and Energy Development Corporation
Key Dates
• 1930 – PIMI’s original transfer certificates of title (TCTs) issued pursuant to Patents Nos. 15–18.
• 1975 – PIMI ceases mining; foreclosure sale transfers titles to MBC/PCIB.
• 2007 – DENR grants Trans-Asia MPSA No. 252-2007-V on July 28; Yinlu claims PIMI patents on August 31.
• May 21, 2009 – DENR Secretary Atienza rules in Yinlu’s favor.
• May 4, 2010 – Office of the President (OP) affirms DENR decision.
• October 30, 2012 – Court of Appeals reverses.
• January 12, 2015 – Supreme Court decision.
Applicable Law
– Philippine Bill of 1902 (mining claim location and patents)
– 1987 Philippine Constitution (effective basis for decisions after 1990)
– Presidential Decree No. 463 (Mineral Resources Development Decree)
– Republic Act No. 7942 (Philippine Mining Act of 1995)
Antecedents
PIMI held 13 placer-type mining patents, four of which (Busser, Superior, Bussamer, Rescue) totaled 192 ha. After PIMI’s 1975 foreclosure, MBC/PCIB obtained new TCTs. From 1986, Trans-Asia explored the area, entered a 1996 agreement with Philex, and secured an MPSA in 2007. Yinlu notified DENR it held pre-1935 patents covering over half the MPSA area; Trans-Asia sought access but was refused.
Administrative Proceedings before the DENR Secretary
DENR Secretary Atienza was asked (1) whether Yinlu’s patents pre-dated the MPSA, and (2) whether they remained valid. On May 21, 2009, he:
- Found PIMI’s 1930 patents were validly issued and transferred to Yinlu.
- Held non‐compliance with PD 463’s registration and improvement obligations did not automatically extinguish those vested rights, especially given PIMI’s force majeure (financial collapse and foreclosure).
- Declared that under the Philippine Bill of 1902, minerals under patented lands were private property, not subject to the Regalian doctrine until post-1935 Constitutions.
- Ordered MPSA No. 252-2007-V amended to exclude Yinlu’s patented lands, subject to compliance with RA 7942 and its IRR.
Trans-Asia’s reconsideration was denied on November 27, 2009.
OP’s Review
On May 4, 2010, the Office of the President:
– Affirmed the DENR Secretary’s decision in toto, reaffirming that placer claims perfected before November 15, 1935 are vested private rights immune from alienation bans in the Constitution;
– Recognized the Torrens titles derived from Act No. 496 and the 1902 Bill as conclusive and indefeasible;
– Upheld that PD 1529 ensured the indefeasibility of titles, even against the government;
– Confirmed that PD 463 could not impair vested rights without specific cancellation;
– Denied Trans-Asia’s motion for reconsideration on June 29, 2010, and again on March 31, 2011 (second motion barred absent exceptional merit).
Court of Appeals Decision
On October 30, 2012, the Court of Appeals reversed, agreeing that Yinlu held pre-1935 patents but ruling that failure to register under PD 463 caused abandonment and lapse of those patents, thus invalidating Yinlu’s claims.
Issues on Supreme Court Appeal
- Whether Trans-Asia’s appeal to the CA was timely.
- Whether Yinlu’s pre-1935 mining patents remain valid, existing, and superior to a subsequent MPSA.
- Nature of Yinlu’s titles (mining patents vs. homestead).
- Whether the sale to Yinlu included minerals in situ.
- Protection of Yinlu’s private-property rights under the Constitution.
- Applicability of laches to titled property.
- Impact on the Republic’s share in natural resources.
Procedural Ruling: Tardiness of Trans-Asia’s Appeal
– Rule 43, Sec. 4 requires appeals within 15 days from notice of denial of the first motion for reconsideration; only one such motion is allowed absent exceptional merit.
– Trans-Asia received notice on July 14, 2010 and should have appealed by July 29, 2010, but filed only on May 11, 2011—well beyond the reglementary period.
– The second motion for reconsideration did not toll the appeal period once the OP deemed it “clearly unmeritorious.”
– The CA therefore lacked jurisdiction to entertain Trans-Asia’s tardy petition for review.
Substantive Ruling: Vested Nature of Pre-1935 Mining Patents
– Under the Philippine Bill of 1902 (Secs. 21 & 27), valid mining claims and patents perfected before November 15, 1935 were private property, segregated from the public domain, granting exclusive possession
Case Syllabus (G.R. No. 207942)
Antecedents of the Dispute
- Thirteen mining claims located in Barrio Larap, Municipality of Jose Panganiban, Camarines Norte, originally owned and operated by Philippine Iron Mines, Inc. (PIMI) until cessation of operations in 1975 due to financial losses.
- Foreclosure sale (December 20, 1975) of PIMI’s Larap Mines to Manila Banking Corporation (MBC) and Philippine Commercial and Industrial Bank (PCIB, later Banco de Oro/BDO).
- Technical feasibility and exploration studies by Bureau of Mines in 1976; subsequent exploration by Benguet-Getty Consortium (1978–1982) and by Trans-Asia Oil and Energy Development Corporation (from 1986).
- 1996 operating agreement between Trans-Asia and Philex Mining Corporation, registered with DENR Regional Office No. V.
- 1997 application (amended 1999) by Trans-Asia for Mineral Production Sharing Agreement (MPSA) over the Larap area; MPSA No. 252-2007-V granted July 28, 2007, giving exclusive exploration, development and utilization rights.
Yinlu’s Acquisition of Mining Patents
- August 31, 2007: Yinlu Bicol Mining Corporation notified the DENR it acquired PIMI’s pre-1935 mining patents via Deed of Absolute Sale from MBC/BDO.
- Four Transfer Certificates of Title (TCTs Nos. 72336–72339) covering four placer claims (Busser Patent No. 15; Superior Patent No. 16; Bussamer Patent No. 17; Rescue Patent No. 18) aggregated 192 hectares—over half of Trans-Asia’s MPSA area.
- Yinlu’s claim that its TCTs evidenced valid, subsisting mining patents issued in 1930, protected as private property under the Philippine Bill of 1902.
Initial DENR Proceedings
- September 2007: Trans-Asia requested access to areas within Yinlu’s patents; Yinlu denied access to its private patent lands.
- DENR Regional Office V placed registration of Trans-Asia’s MPSA on hold pending verification of Yinlu’s patents.
- November 29, 2007: DENR Regional Office V reported no record of Yinlu’s mining patents; parties invited to submit position papers.
- Issues posed to DENR Secretary (1) existence and priority of Yinlu’s patents pre-dating MPSA; (2) validity and subsistence of said patents.
DENR Secretary’s Decision (May 21, 2009)
- Found mining patents issued to PIMI in 1930, validly transferred to Yinlu.
- Rejected Trans-Asia’s arguments of abandonment for failure to register under PD No. 463 and to perform improvements:
• No specific DENR cancellation order of patents.
• Improvement and registration requirements under the Philippine Bill of 1902 not absolute; force majeure (PIMI’s financial losses, foreclosure) excused non-complia