GR 112916; (March, 1995) (Digest)
G.R. No. 112916 March 16, 1995
SCOTT CONSULTANTS & RESOURCE DEVELOPMENT CORPORATION, INC., petitioner, vs. COURT OF APPEALS and PHILIPPINE ROCK PRODUCTS, INC., respondents.
FACTS
Petitioner Scott Consultants & Resource Development Corporation, Inc. entered into an Option Agreement with Kadakilaan Estate and an agreement with San Mateo Mines Exploration, Inc. (SMMEI) to develop and operate mining claims in Rodriguez, Rizal. Private respondent Philippine Rock Products, Inc. (Philrock) had a prior operating agreement with SMMEI, which SMMEI unilaterally terminated before entering into the agreement with petitioner. Petitioner filed a complaint alleging that Philrock prevented it from accessing and developing the mining claims, causing damages. The trial court issued a writ of preliminary mandatory injunction, later dissolved upon Philrock’s filing of a bond. Philrock filed a Third-Party Complaint against SMMEI and landowners intervened. The trial court ruled that petitioner had the right to conduct mining activities but could not use the access routes constructed by Philrock on private lands without Philrock’s permission. It awarded Philrock actual, exemplary damages, and attorney’s fees. The Court of Appeals affirmed the trial court’s decision but deleted the award of actual damages, reducing exemplary damages and attorney’s fees.
ISSUE
The core issue is whether the petitioner is entitled to conduct exploration and similar activities within the mining claims and use the access routes constructed by the private respondent.
RULING
The Supreme Court partly granted the petition. It affirmed that the petitioner has the right to conduct mining exploration and development activities on the mining claims by virtue of its agreements with the registered locators, subject to the rights of the landowners and occupants. However, the petitioner cannot use the access routes constructed by Philrock on private lands, as Philrock acquired exclusive easement rights from the landowners. The Court deleted the awards of actual damages, exemplary damages, and attorney’s fees to Philrock for lack of factual and legal basis. The actual damages were not proven with reasonable certainty, exemplary damages were not warranted in the absence of entitlement to moral, temperate, or compensatory damages, and the award of attorney’s fees lacked explicit legal justification in the body of the decision.