G.R. No. L-47859, L-57132 October 30, 1981
SAN MAURICIO MINING COMPANY, MARSMAN AND COMPANY, INC., and PEDRO L. MOYA, petitioners-appellants, vs. HONORABLE CONSTANTE A. ANCHETA, as Presiding Judge of Branch III, Court of First Instance of Camarines Norte, PHILIPPINE SMELTERS CORPORATION, NATIONAL SHIPYARDS AND STEEL CORPORATION, DIRECTOR OF LANDS, COMMISSIONER OF LAND REGISTRATION and REGISTER OF DEEDS OF CAMARINES NORTE, respondents-appellees.

FACTS

Petitioners San Mauricio Mining Company and Marsman & Company, Inc. claimed ownership over certain mining lands based on rights allegedly acquired under the Philippine Bill of 1902. The core dispute centered on the validity of Presidential Decree No. 837, which granted titles over the subject lands to respondent Philippine Smelters Corporation, and the legal effect of a series of transactions involving the petitioners and the National Shipyards and Steel Corporation (NASSCO). The petitioners initially appealed a partial summary judgment and an execution order to the Supreme Court. Subsequently, upon agreement, the trial court was allowed to proceed and render a final judgment, which was then appealed to the Court of Appeals. The cases were later consolidated before the Supreme Court for a joint decision.
The trial court found that petitioners had sold their mining rights to NASSCO via a Deed of Absolute Sale dated November 19, 1957. It further held that a later attempted reconveyance from NASSCO back to the petitioners in 1973 was invalid, as NASSCO was then merely an administrator of the property under a presidential proclamation and lacked the authority to sell. The trial court thus ruled against the petitioners, upholding the titles issued to Smelters under P.D. No. 837.

ISSUE

The primary issue was whether the petitioners retained valid, existing private rights over the mining claims that should have been respected and excluded from the coverage of P.D. No. 837, which granted the lands to respondent Smelters.

RULING

The Supreme Court denied the petitioners’ motion for reconsideration and affirmed the trial court’s decision. The legal logic centered on the petitioners’ failure to substantiate their claim of existing private rights. The Court found the 1957 Deed of Absolute Sale to NASSCO as the pivotal document, which effectively divested the petitioners of their mining rights. The Court rejected the petitioners’ argument that this deed only conveyed surface rights, emphasizing that they failed to properly plead and prove this assertion at trial. The rule on actionable documents placed the burden on the petitioners, as parties to the deed, to allege and prove any variance between the document’s terms and the true intent of the parties. Their omission to do so was fatal.
Furthermore, the Court held that the subsequent 1973 reconveyance from NASSCO was ultra vires and void, as NASSCO’s authority at the time was merely administrative under a subsisting proclamation. Since the petitioners had already alienated their rights in 1957, they had no remaining private rights by the time P.D. No. 837 was issued. Therefore, the decree could validly grant the lands, considered part of the public domain, to Smelters. The Court also clarified that the petitioners’ appeal, having originated from a review of a partial summary judgment, was limited to questions of law, and the factual findings of the trial court, supported by evidence, were conclusive. The invocation of denial of due process was unfounded, as the petitioners had every opportunity to present their case and evidence but failed to properly do so regarding the 1957 deed.