G.R. No. 173562 ; January 22, 2008
CENTRAL CEMENT CORPORATION (now Union Cement Corporation), petitioner, vs. MINES ADJUDICATION BOARD and ROCK AND ORE INDUSTRIES, INC., respondents.

FACTS

Petitioner Central Cement Corporation (CCC) and respondent Rock and Ore Industries, Inc. (ROII) are mining companies with conflicting Mineral Production Sharing Agreement (MPSA) applications. The Panel of Arbitrators dismissed CCC’s adverse claim as filed beyond the reglementary period, a decision affirmed by the Mines Adjudication Board (MAB). During the pendency of CCC’s motion for reconsideration before the MAB, the President of ROII informed the MAB that a Memorandum of Understanding (MOU) had been executed between Union Cement Corporation (UCC, the surviving corporation from a merger with CCC) and Eagle Cement Corporation (ECC, which shared controlling interests with ROII). The MOU provided for a reciprocal cession and swapping of the disputed mining claims.
CCC, in a Manifestation, acknowledged the MOU’s existence and its binding effect due to the merger but requested the MAB to hold the dismissal of the appeal in abeyance. CCC argued the settlement was premature as the swapping of claims under the MOU had yet to be consummated, and the parties instead agreed to later submit a joint motion to dismiss. The MAB directed the parties to iron out differences and file a joint motion. After the parties failed to comply, the MAB issued a resolution dismissing CCC’s motion for reconsideration, effectively terminating the case based on the MOU.

ISSUE

Whether the MAB acted with grave abuse of discretion in dismissing the case based on the compromise MOU despite CCC’s request for deferment pending the submission of a joint motion to dismiss.

RULING

The Supreme Court ruled that the MAB did not commit grave abuse of discretion. The right to a speedy disposition of cases is constitutionally guaranteed and applies to quasi-judicial bodies like the MAB. While CCC requested a hold in abeyance, it unconditionally admitted the MOU’s genuineness, due execution, and its binding effect. A compromise agreement, as defined under Article 2028 of the Civil Code, is a contract whereby the parties make reciprocal concessions to resolve a litigation. The essential elements of a contract—consent, object, and cause—were present in the MOU as admitted by CCC. The Court emphasized that a compromise is itself a definitive resolution of the parties’ differences; it does not require full performance or execution to be valid and effective for the purpose of dismissing the pending action. The fact that certain details within the MOU’s framework remained to be implemented did not negate its finality as a settlement. By dismissing the motion for reconsideration, the MAB rightly gave effect to the compromise, thereby preventing further delay. The Court affirmed the Court of Appeals’ decision upholding the MAB’s resolution.