G.R. No. L-60494 June 8, 1988
MATEO BACALSO and CESAR GONZALES, petitioners, vs. HONORABLE COURT OF APPEALS and CELESTINO BACALSO, respondents.

FACTS

Private respondent Celestino Bacalso filed an action in the Court of First Instance of Cebu to enjoin the Secretary of Agriculture and Natural Resources from approving the mining lease applications of petitioners Mateo Bacalso and Cesar Gonzales over claims designated as Mateo 1 to 10. The complaint alleged that the prior administrative decisions of the Director of Mines and the Secretary, which favored the petitioners, were rendered without jurisdiction or with grave abuse of discretion because they disregarded Celestino’s prior valid mining claims and lease applications over the same area, known as Elizabeth 1 to 10. The trial court and the Court of Appeals upheld Celestino’s position, declaring the administrative decisions null and void and ordering the approval of his lease applications.
The petitioners argued that the trial court lacked jurisdiction over the case. They contended that the dispute was a conflict over mining locations governed by Section 61 of the Mining Act ( C.A. No. 137 , as amended). Under this provision, such conflicts must first be submitted to the Director of Mines, with appeals possible to the Secretary and then to a competent court within a strict 30-day period. They asserted that Celestino’s court action, filed beyond this reglementary period, was improper, rendering the administrative decisions final.

ISSUE

The primary issue is whether the trial court had jurisdiction to entertain Celestino Bacalso’s action to nullify the administrative decisions of the Director of Mines and the Secretary of Agriculture and Natural Resources, or whether the dispute was exclusively governed by the appeal procedure under Section 61 of the Mining Act.

RULING

The Supreme Court granted the petition, reversed the decisions of the lower courts, and reinstated the administrative decisions. The Court held that the trial court indeed lacked jurisdiction. The allegations in Celestino’s complaint unequivocally revealed a conflict arising from mining locations—specifically, a dispute over who had valid discovery and location rights over the contested area. Such a conflict falls squarely under Section 61 of the Mining Act, which mandates a specific hierarchical procedure: initial submission to the Director of Mines, appeal to the Secretary within 30 days, and a further appeal to a competent court, also within 30 days from receipt of the Secretary’s decision.
The Court clarified the distinction between two proceedings under the Mining Act. The first, under Section 61, covers conflicts arising from mining locations themselves, which is the scenario here. The second, under Sections 72 and 73, governs the filing of adverse claims after the publication of a notice of a lease application. Since Celestino’s lease applications had not yet undergone the publication required by Section 72 at the time the petitioners filed their protest, the dispute remained a location conflict properly cognizable by the Director of Mines under Section 61. Consequently, the Director had jurisdiction to hear and decide the case. Celestino’s failure to appeal the Secretary’s final decision to a competent court within the 30-day period prescribed by Section 61 rendered that administrative decision final and binding, stripping the trial court of any authority to review or nullify it on the merits.