G.R. No. 17597 , December 29, 1922
E. W. McDaniel, petitioner, vs. Galicano Apacible, Secretary of Agriculture and Natural Resources, and Juan Cuisia, respondents.

FACTS

Petitioner E. W. McDaniel, on behalf of an association, validly located three petroleum placer claims (“Maglihi” claims) on public land in 1916 under the then-existing mining laws. In 1917, the other association members transferred their interests to McDaniel. He performed annual assessment work and, in 1918, drilled wells on the claims, making discoveries of petroleum. In 1921, respondent Juan Cuisia applied for a petroleum lease under Act No. 2932, which covered the same lands as McDaniel’s claims. The Secretary of Agriculture and Natural Resources denied McDaniel’s protest against the inclusion of his claims in the lease application. McDaniel filed a petition for prohibition, arguing Act No. 2932 was unconstitutional as applied to his valid pre-existing claims, as it would deprive him of property without due process. The parties stipulated facts, including that McDaniel expended P12,000 in development and that the original locations were valid.

ISSUE

Whether Act No. 2932 of the Philippine Legislature can be applied to validly located mineral claims, discovered and held prior to its enactment, thereby depriving the locator of his rights without due process of law.

RULING

No. The Supreme Court granted the writ of prohibition. Act No. 2932 is void insofar as it applies to valid mineral locations made prior to its enactment and upon which the required annual assessment work has been performed. A valid location of a mining claim under the law then in force constitutes a property right vested in the locator. To apply Act No. 2932 to such pre-existing valid claims and lease them to another would deprive the locator of his property without due process of law and without compensation. The Court’s decision is based on the stipulated facts and admissions showing valid prior location, expenditure, and development in good faith, with no forfeiture for failure to perform assessment work pleaded or proven.