GR 108846; (October, 1999) (Digest)
G.R. No. 108846 . October 26, 1999.
MOOMBA MINING EXPLORATION COMPANY, represented by Minimax Mineral Exploration Corporation, petitioner, vs. THE HON. COURT OF APPEALS, CORNELIO TUMULAK and TERESA C. CORPUS, represented by JOAQUIN P. CORPUZ, respondents.
FACTS
Petitioner Moomba Mining Exploration Company registered its “Rocky 1-100” mining claims in 1973. Its subsequent availment application under Presidential Decree No. 463 was rejected by the Bureau of Mines and Geo-Sciences (BMGS) in 1979 for non-compliance with requirements. Meanwhile, after this rejection, private respondents Cornelio Tumulak and Teresa Corpus registered their own mining claims, “Golden Bay” and “Baby Jackie,” covering areas within Moomba’s previously rejected claims. In 1981, the BMGS Director partially granted Moomba’s request for reconsideration but upheld the validity of the private respondents’ claims as intervening rights over specific “Rocky” claims. Later, Moomba itself filed a manifestation with the BMGS, stating it had concluded that the private respondents’ claims were validly located and constituted intervening rights, and manifested its lack of interest to pursue the case.
Despite Moomba’s manifestation, Minimax Mineral Exploration Corporation, representing itself as Moomba’s operator under a royalty agreement, continued to appeal the administrative orders recognizing the private respondents’ claims. These appeals to the Department of Environment and Natural Resources (DENR) Secretary and the Office of the President were dismissed. Minimax, still representing Moomba, then filed a petition for certiorari with the Supreme Court, which was referred to the Court of Appeals. The Court of Appeals dismissed the petition, ruling that the assailed administrative decisions involved findings of fact and that any error committed was at most an error of judgment, not jurisdiction, which is not correctible by certiorari.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for certiorari and in upholding the administrative decisions which recognized the private respondents’ mining claims as valid intervening rights.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core issue raised by the petitioner was ultimately factual: the validity of the private respondents’ intervening mining claims and Moomba’s own recognition of them. A petition for review on certiorari under Rule 45, which this case is, limits the Court’s review to questions of law. The Court is not a trier of facts and will not re-examine or weigh the evidence already evaluated by the administrative agencies and the Court of Appeals. The findings of the BMGS, the DENR Secretary, and the Office of the President, which were all congruent in recognizing the private respondents’ claims, are accorded great respect and finality. Administrative agencies possess specialized technical knowledge in their fields, and their factual determinations are binding absent a showing of insufficient or insubstantial evidence, which was not present here. The petitioner’s arguments, including those questioning the unilateral termination of its agreement with Minimax and the authority of a partner to act for the partnership, were ancillary to the central factual issue already settled. The Court found no reversible error in the Court of Appeals’ decision dismissing the petition for lack of merit.
