GR 149927; (March, 2004) (Digest)
G.R. No. 149927; March 30, 2004
Republic of the Philippines, et al. vs. Rosemoor Mining and Development Corporation, et al.
FACTS
Respondents discovered marble deposits in Bulacan and were subsequently issued Quarry License/Permit (QLP) No. 33 by the Bureau of Mines, covering 330.3062 hectares. The license was later cancelled by then DENR Minister Ernesto Maceda in 1986. Respondents filed a case challenging the cancellation. The trial court ruled in their favor, declaring the cancellation void for violating due process as it was done without notice and hearing, and held that the license had ripened into a vested property right. This decision was affirmed by the Court of Appeals. The CA further held that the license was valid as it stemmed from four separate applications, each for 81 hectares, and that the 100-hectare limit per quarry license under Presidential Decree No. 463 had been supplanted by a subsequent law.
ISSUE
The primary issue is whether QLP No. 33 was issued in contravention of Section 69 of P.D. No. 463, which limits a quarry license to an area not exceeding 100 hectares in any one province. A corollary issue is the validity of its administrative cancellation.
RULING
The Supreme Court granted the petition and reversed the lower courts. The Court held that QLP No. 33 was void from the beginning because it violated the explicit and mandatory 100-hectare limit under Section 69 of P.D. No. 463. The license covered 330.3062 hectares in a single province, which was a patent violation of the law. The argument that it was based on four separate applications was untenable; the law clearly refers to the total area granted under one license, not the number of applications. A mining license is a mere privilege granted by the State, not a contract, and it confers no absolute or vested rights. Being an administrative issuance that contravened the law under which it was supposedly granted, it was inherently void. Consequently, the State could revoke such a void license without violating the due process or non-impairment clauses of the Constitution. Since the license was null ab initio, respondents acquired no property right from it. The cancellation was therefore a valid exercise of the State’s police power and regulatory authority over the country’s natural resources. The Court emphasized that the State has the right and duty to annul void contracts or licenses, especially those pertaining to the exploitation of public domain.