G.R. No. L-49109 December 1, 1987
SANTA ROSA MINING COMPANY, INC., petitioner, vs. HON. MINISTER OF NATURAL RESOURCES JOSE J. LEIDO, JR. AND DIRECTOR OF MINES JUANITO C. FERNANDEZ, respondents.

FACTS

Petitioner Santa Rosa Mining Company, Inc., holder of fifty mining claims located under the Philippine Bill of 1902, filed a special civil action for certiorari and prohibition to declare Presidential Decree No. 1214 unconstitutional. The decree required holders of such claims to file a mining lease application within one year, waiving their right to a patent. Petitioner filed its application “under protest” while simultaneously petitioning the Court, arguing the decree constituted a deprivation of property without due process. It cited final judgments from the Court of First Instance of Camarines Norte in land registration cases involving third parties, where the courts recognized petitioner’s mining claims as vested property.
Respondents, the Minister of Natural Resources and the Director of Mines, countered that petitioner failed to exhaust administrative remedies. They highlighted a pending appeal before the Office of the President from a decision in DNR Case No. 4140, wherein the Secretary of Natural Resources ruled that forty-four of petitioner’s claims were void for lack of valid “tie points” and all claims were deemed abandoned for non-compliance with assessment requirements under the Philippine Bill of 1902 and Executive Order No. 141.

ISSUE

Whether the Supreme Court could entertain petitioner’s constitutional challenge against Presidential Decree No. 1214 despite the pending administrative appeal regarding the validity and status of its mining claims.

RULING

The Supreme Court dismissed the petition, upholding the principle of exhaustion of administrative remedies. The Court ruled it was premature to adjudicate the constitutional issue because a prerequisite factual question—the validity and subsistence of petitioner’s mining claims—was pending resolution before the Office of the President. The Court cited Ham v. Bachrach Motor Co., Inc., stating that a party who appeals an administrative decision cannot seek judicial intervention before the appeal is concluded.
The Court clarified that the cited CFI decisions in land registration cases did not constitute a final adjudication on the continuing validity of petitioner’s unpatented mining claims under mining laws. Those decisions merely denied third-party applications over the same land, finding the applicants lacked registrable title. They did not definitively rule that petitioner had maintained its claims in compliance with all legal requirements for perfection and maintenance. Therefore, the administrative proceeding (DNR Case No. 4140) to determine possible abandonment was not foreclosed. Since the very existence of a valid property right subject to deprivation by the decree was still administratively contested, petitioner lacked standing to mount a constitutional challenge at that stage. The Court did not reach the merits of the decree’s constitutionality.