G.R. No. 148267, August 8, 2002
ARMANDO C. CARPIO, petitioner, vs. SULU RESOURCES DEVELOPMENT CORPORATION, respondent.

FACTS

This case originated from a petition filed by respondent Sulu Resources Development Corporation for a Mines Production Sharing Agreement (MPSA) covering areas in Antipolo, Rizal. Petitioner Armando C. Carpio filed an opposition/adverse claim, alleging his landholdings would be covered by respondent’s claim and that he enjoyed a preferential right to explore and extract quarry resources on his properties. The Panel of Arbitrators of the Mines and Geo-Sciences Bureau rendered a Resolution dated September 26, 1996, upholding petitioner’s opposition/adverse claim and ordering the exclusion of his properties from the MPSA area. Respondent appealed to the Mines Adjudication Board (MAB), which, on June 20, 1997, issued an Order setting aside the Panel of Arbitrators’ Resolution and dismissing petitioner’s adverse claim/opposition. Petitioner’s motion for reconsideration was denied by the MAB on November 24, 1997. Petitioner then filed a petition for review with the Court of Appeals. The CA denied the petition, ruling it did not have jurisdiction to review the MAB Decision. The CA cited Section 79 of the Philippine Mining Act of 1995 (RA 7942), which states that the findings of fact and decisions of the MAB are final and executory, and that a petition for review by certiorari on questions of law may be filed directly with the Supreme Court. Hence, petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45.

ISSUE

Whether appeals from the Decision or Final Orders of the Mines Adjudication Board should be made directly to the Supreme Court or first to the Court of Appeals.

RULING

The Supreme Court ruled that appeals from decisions and final orders of the Mines Adjudication Board (MAB) are appealable to the Court of Appeals under Rule 43 of the 1997 Rules of Court. The Petition is meritorious. The Court held that the MAB is unquestionably a quasi-judicial agency, and its decisions fall under the uniform rule of appellate procedure provided by Rule 43. The Court clarified that its prior ruling in Pearson v. Intermediate Appellate Court was inapplicable, as that case involved a petition for certiorari under Rule 65 challenging a Court of First Instance order, not a petition for review under Rule 43 of a MAB decision. The Court further held that statutory provisions purporting to make quasi-judicial agency decisions directly appealable only to the Supreme Court, such as Section 79 of the Philippine Mining Act, are unconstitutional as they broaden the Court’s appellate jurisdiction without its consent, violating Section 30, Article VI of the Constitution, and are invalidated by the Court’s rule-making power under the Constitution. The Court cited analogous rulings in Fabian v. Desierto, which struck down a similar provision in the Ombudsman Act, and other cases involving the Commission on Settlement of Land Problems and the Construction Industry Arbitration Commission. Consequently, the Court of Appeals erred in dismissing the petition for lack of jurisdiction. The case was remanded to the Court of Appeals for proper proceedings.