G.R. No. L-57665 July 2, 1990
ALEJA SIBAYAN VDA. DE PINEDA, CLARA SIBAYAN VDA. DE GADDI, and MIGUELA SIBAYAN RAMENTO, petitioners, vs. THE HON. TEODORO PEÑA, MINISTER OF NATURAL RESOURCES; THE HON. JUANITO FERNANDEZ, DIRECTOR OF MINES & GEO-SCIENCES; and the KM. 21 MINING EXPLORATION CORPORATION; THE BAGUIO GOLD MINING COMPANY, INC.; ELVIRA DE CARMELO and JOSEPH PALENGAOAN, respondents.

FACTS

This case originated from a protest before the Bureau of Mines (Mines Administrative Case No. V-784) filed by petitioners, heirs of the original locator, alleging that the “Ullmann” mining claim encroached upon their “Ped” claim. The “Ped” claim was located in 1932. Petitioners’ ownership was previously contested in a separate civil case (Civil Case No. Q-17136), which was settled amicably in 1974. The settlement stipulated that private respondents would return the “Ped” claim to petitioners upon reimbursement of expenses like assessment taxes. Meanwhile, Presidential Decree No. 463 (The Mineral Resources Development Decree of 1974) took effect, requiring holders of old mining claims to file an application for recognition within two years to preserve their rights.
The Director of Mines dismissed the protest, finding no physical overlap between the claims. However, the decision also declared that petitioners had abandoned and lost their rights over the “Ped” claim for failure to file the required application under P.D. No. 463 and for alleged non-performance of annual work obligations. This finding was affirmed by the Minister of Natural Resources. Petitioners assailed this portion of the decision via certiorari and prohibition.

ISSUE

Whether public respondents committed grave abuse of discretion in declaring that petitioners had abandoned and lost their rights over the “Ped” mining claim.

RULING

Yes, public respondents committed grave abuse of discretion. The Supreme Court clarified that while the Director of Mines had the authority under P.D. No. 463 to ascertain the validity of the “Ped” claim, the finding of abandonment was baseless. On the requirement to file an application for recognition, the Court noted that the protest case itself, filed by petitioners to assert their rights over the “Ped” claim, substantially complied with the law’s intent to have old claims recognized and registered.
More critically, the finding of non-performance of annual work obligations was erroneous. Records showed that the annual assessment taxes and work obligations on the “Ped” claim had been paid up to 1975 by the Baguio Gold Mining Company, to which the claim had been assigned for operation by private respondents. Subsequently, petitioners themselves paid the taxes due up to 1981. This payment by the assignee inured to the benefit of petitioners. Furthermore, the 1974 amicable settlement in the civil case, which was final, explicitly placed the obligation to pay past preservation expenses on private respondents, with petitioners only liable for reimbursement. Therefore, petitioners could not be faulted for non-payment for the years in question. Public respondents’ disregard of these material facts constituted grave abuse of discretion. The assailed portion of the decision was declared null and void.