GR L 65021; (November, 1991) (Digest)
G.R. No. L-65021 November 21, 1991
BENGUET CORPORATION, petitioner, vs. HON. OSCAR L. LEVISTE, in his capacity as Presiding Judge of the Regional Trial Court (National Capital Judicial Region, Branch XCVII, Quezon City) and HELEN DIZON-REYES, respondents.
FACTS
Private respondent Helen Dizon-Reyes, owner of 11 mining claims in Zambales, filed a complaint before the Regional Trial Court (RTC) of Quezon City against Benguet Corporation and Dizon Copper-Silver Mines, Inc. She sought the annulment of an Operations Agreement executed between the two corporations in 1975. Her claims were based on the alleged lack of legal basis for the agreement due to the prior revocation of the special power of attorney granted to her father, who had originally entered into a mining agreement with Dizon Mines on her behalf in 1967. She also challenged the efficacy of a subsequent Deed of Ratification she had signed.
Benguet Corporation filed a Motion to Dismiss, primarily arguing that the RTC lacked jurisdiction over the subject matter. It contended that under Presidential Decree No. 1281, exclusive original jurisdiction over actions for the cancellation of mining contracts is vested in the Bureau of Mines and Geo-Sciences. The RTC denied the motion to dismiss, prompting Benguet to file the instant petition for certiorari and prohibition.
ISSUE
Whether the Regional Trial Court has jurisdiction over an action for the annulment of a mining operations agreement.
RULING
The Supreme Court granted the petition and dismissed the civil case. The Court held that the RTC had no jurisdiction; exclusive original jurisdiction was vested in the Bureau of Mines and Geo-Sciences. The legal logic is anchored on a clear statutory grant and the doctrine of primary jurisdiction. Section 7(c) of P.D. No. 1281 explicitly confers upon the Bureau of Mines exclusive original jurisdiction over “actions for cancellation and/or enforcement of mining contracts due to the refusal of the claimowner/operator to abide by the terms and conditions thereof.”
The Court rejected the respondent’s argument that an action for annulment based on nullity falls outside this provision. It ruled that the nature of the action is determinative. Since the ultimate objective of the complaint was to cancel the Operations Agreement, the case fell squarely within the Bureau’s jurisdiction. The alleged grounds for annulment—such as lack of authority or defective consent—are merely the reasons for seeking cancellation and do not alter the action’s fundamental character as one for the cancellation of a mining contract. To hold otherwise would create a split jurisdiction, allowing judicial and administrative bodies to adjudicate essentially the same subject matter, which is contrary to orderly justice administration. Consequently, the trial court committed grave abuse of discretion in assuming jurisdiction. The other grounds raised by petitioner were deemed immaterial or factual, requiring no resolution.