G.R. No. 63786 -87, G.R. No. 70423, G.R. No. 73931 . April 7, 1993.
Case Parties:

1. G.R. No. 63786 -87: UNITED PARACALE MINING COMPANY, INC., AND COCO GROVE, INC., petitioners, vs. HON. JOSELITO DELA ROSA, in his capacity as the former Judge of the Court of First Instance of Camarines Norte, Branch 2, et al., respondents.
2. G.R. No. 70423: ZAMBALES CHROMITE MINING COMPANY, INC., petitioner, vs. HON. ALFREDO L. BENIPAYO, as Judge, Regional Trial Court of Manila, and PHILZEA MINING & DEVELOPMENT CORPORATION, respondents.
3. G.R. No. 73931 : JOSEPH V. LOPEZ and MIGUEL C. ANDRADE, petitioners, vs. THE INTERMEDIATE APPELLATE COURT, MARSMAN & COMPANY, INC. and UNITED PARACALE MINING COMPANY, INC., respondents.

FACTS

The consolidated petitions involve issues related to mining claims and jurisdiction. In G.R. No. 73931 , petitioners Joseph V. Lopez and Miguel C. Andrade sought to enjoin the Regional Trial Court (RTC) from issuing a preliminary injunction in a case filed by Marsman & Company, Inc. and United Paracale Mining, Inc., which aimed to stop the petitioners from conducting mining operations within certain tunnels in Camarines Norte. The petitioners argued that the private respondents had forfeited their rights to the mining claims under P.D. 1214 and that the RTC lacked jurisdiction under P.D. 605. They also moved for the disqualification of the judge. The RTC suspended the hearing pending resolution of the motion to dismiss, and the Intermediate Appellate Court denied the petition for certiorari and prohibition.
In G.R. No. 70423, petitioner Zambales Chromite Mining Company, Inc. filed a complaint in the CFI of Manila for rescission of a mining contract with private respondent Philzea Mining & Development Corporation. The trial court dismissed the complaint for lack of jurisdiction, citing Section 7 of P.D. 1281, which vests original and exclusive jurisdiction over mining disputes in the Director of Mines.
In G.R. Nos. 63786-87, the petitioners challenged the constitutionality of P.D. 1214 and argued that their mining claims, registered under the Philippine Bill of 1902 and Act No. 624 , had become private property and were thus outside the jurisdiction of the Director of Mines.

ISSUE

1. Whether the registration of mining claims under the Philippine Bill of 1902 and Act No. 624 converts them into private property, thereby removing them from the jurisdiction of the Director of Mines.
2. Whether P.D. 1214 is constitutional.
3. Whether regular courts have jurisdiction over cases involving mining disputes, specifically the enforcement or rescission of mining contracts, in light of P.D. 1281.
4. Whether the Intermediate Appellate Court committed reversible error in G.R. No. 73931 .

RULING

1. On the nature of registered mining claims: The Supreme Court ruled that the registration of mining claims under the Philippine Bill of 1902 and Act No. 624 does not transform them into private property. The law (P.D. 1281) does not distinguish between private property and public domain lands. The Court emphasized that statutory construction is only proper when there is doubt or ambiguity in the language of the law. Since Section 7 of P.D. 1281 is clear and categorical, it must be applied as written. Mere location does not confer absolute ownership; it only segregates the land from the public domain.
2. On the constitutionality of P.D. 1214: The Court upheld the constitutionality of P.D. 1214, following its previous rulings in Santa Rosa Mining Company, Inc. vs. Leido, Jr. and Zambales Chromite Mining Company, Inc. vs. Leido, Jr. The decree is a valid exercise of the state’s sovereign power as owner of public lands and the nation’s patrimony. It applies only to mining claims where locators failed to obtain a patent, and such locators may still avail of a renewable 25-year lease under P.D. 463. The decree aligns with the constitutional mandate for state control and supervision of natural resources.
3. On jurisdiction over mining disputes: The Court affirmed that under P.D. 1281, the Director of Mines has original and exclusive jurisdiction over mining disputes, including actions for the enforcement or rescission of mining contracts. Regular courts lack jurisdiction over such matters. The dismissal of the complaint in G.R. No. 70423 was proper.
4. On G.R. No. 73931 : The Court found no reversible error or grave abuse of discretion by the Intermediate Appellate Court. The petitioners failed to properly raise questions of law and instead discussed irrelevant matters. The issues raised were defenses that should be addressed in the main action, and the question of jurisdiction was prematurely raised. The petition was insufficient in substance and form.
DISPOSITIVE PORTION:
The petitions in G.R. No. 73931 and G.R. No. 70423 were DISMISSED for lack of merit. The Order of dismissal assailed in G.R. Nos. 63786-87 was AFFIRMED, and these petitions were likewise DISMISSED. No costs.