G.R. No. L-30504 August 29, 1974
Constancia D. Vega, petitioner, vs. Honorable Fernando Lopez, in his capacity as the Secretary of Agriculture and Natural Resources, and Atlas Consolidated Mining and Development Corporation, respondents.

FACTS

The case involves a conflict over twelve overlapping mining claims in Toledo, Cebu. Respondent Atlas Consolidated Mining and Development Corporation (Atlas) based its claim on locations and registrations made by its predecessors-in-interest, Zenon Panimdim and Simon C. Dumaguing, between April and July 1953, with deeds of sale to Atlas executed in 1954 and 1955. Atlas filed its lode lease application in 1957. Petitioner Constancia D. Vega based her claim on locations made by her attorney-in-fact, Gregorio Ravago, in August 1957, with the corresponding declarations registered that same month. Vega filed her lease applications thereafter.
Atlas initiated a protest before the Bureau of Mines (Mines Administrative Case No. V-262). Vega initially refused to submit to the Bureau’s jurisdiction, leading to a decision in favor of Atlas based on ex parte evidence. On appeal, the Secretary of Agriculture and Natural Resources remanded the case for Vega to present evidence. Hearings were conducted where Vega presented her evidence, but Atlas presented no additional proof. The Director of Mines and, on appeal, the Secretary, ruled in favor of Atlas, giving it preferential right to lease the area.

ISSUE

Whether the Secretary of Agriculture and Natural Resources committed reversible error in affirming the decision granting Atlas the preferential right to lease the disputed mining claims.

RULING

The Supreme Court affirmed the decision of the Secretary. The legal logic is anchored on the principle of priority under Section 60 of the Mining Act, as amended. The Court found the Secretary’s factual findings, which established Atlas’s prior location and registration of its claims in 1953, to be amply supported by evidence, including Vega’s own admissions. Since Atlas’s claims were located and registered years before Vega’s claims in 1957, Atlas possessed a clear preferential right. The Court also noted the lack of good faith on Vega’s part, as evidence showed she was aware of Atlas’s prior claims and operations in the adjacent area when she initiated her own locations. The Court found no need to apply the provisions of Presidential Decree No. 99-A, which reinforces the right of the first registrant, as Atlas’s priority was already firmly established under the existing Mining Act. Consequently, no reversible error was committed by the respondent Secretary in his adjudication.