G.R. No. L-49835 December 18, 1979
TWIN PEAKS MINING ASSOCIATION, et al., petitioners, vs. HON. PEDRO C. NAVARRO, Presiding Judge of the Court of First Instance of Rizal, Branch II, and PHILEX MINING CORPORATION, respondents.

FACTS

Philex Mining Corporation filed a complaint in the Court of First Instance of Rizal against Twin Peaks Mining Association and its partners. Philex sought a judicial declaration that two mining agreements from 1970 and 1971, purportedly executed by a geodetic engineer representing himself as Twin Peaks’ general manager, were valid and binding. The agreements concerned the exploration and exploitation of numerous lode mineral claims in Benguet. Twin Peaks moved to dismiss the complaint, arguing the trial court lacked jurisdiction. They contended that under Section 7(c) of Presidential Decree No. 1281, the Bureau of Mines possessed original and exclusive jurisdiction over cases involving the enforcement of mining contracts due to a claimowner’s refusal to abide by their terms.
The trial court denied the motion to dismiss, ruling the validity of the contracts was a justiciable question for the courts. Twin Peaks then filed the instant special civil actions of certiorari and prohibition. Notably, the Bureau of Mines, through an amicus curiae brief, supported Twin Peaks’ position. It was revealed that the Assistant Director of Mines had already rejected Philex’s applications for availment of rights concerning the same claims, citing the lapse of the claims and the lack of authority of the individual who signed the contracts. This rejection order had become final due to Philex’s failure to appeal.

ISSUE

Whether the Court of First Instance has jurisdiction over a complaint seeking the enforcement and declaration of validity of mining contracts, or if such jurisdiction is vested exclusively in the Bureau of Mines under Presidential Decree No. 1281.

RULING

The Supreme Court granted the writ of prohibition, holding that the trial court had no jurisdiction. The legal logic is anchored on the explicit statutory grant of quasi-judicial powers to the Bureau of Mines. Presidential Decree No. 1281, which revised the charter of the Bureau, was enacted to make it a more effective administrative body for mineral resource disposition. Section 7(c) of the decree unequivocally confers upon the Bureau “original and exclusive jurisdiction to hear and decide cases involving … cancellation and/or enforcement of mining contracts due to the refusal of the claimowner/operator to abide by the terms and conditions thereof.” The Court found that Philex’s complaint, though framed as one for declaratory relief, ultimately sought the enforcement of the disputed mining agreements, a matter falling squarely within the Bureau’s exclusive domain. This conclusion was bolstered by Philex’s own prior conduct in submitting an application for availment of rights to the Bureau, an implicit admission of the Bureau’s adjudicatory authority over the subject matter. The Court further noted the legislative trend, evident in post-martial law decrees, to make the adjudication of mining disputes a purely administrative matter, with appeals routed to the Secretary of Natural Resources and then to the President, not the courts. Consequently, the trial court’s order was reversed and the complaint was ordered dismissed for lack of jurisdiction.