GR L 69261; (May, 1985) (Digest)
G.R. No. L-69261 May 13, 1985
RAJAH LAHUY MINING COMPANY and WEST PACIFIC RICH MINERALS, INC., petitioners, vs. JUDGE JAMES B. PAJARES, Regional Trial Court, Naga City, Branch 19, RAQUEL ENRIQUEZ y ALVAREZ, MA. RAMONA ARENILLO y ALVAREZ, EMILY STA. ANA y ALVAREZ and DIRECTOR OF MINES AND GEOSCIENCES, respondents.
FACTS
Private respondents Raquel Enriquez, Ma. Ramona Arenillo, and Emily Sta. Ana are the registered co-owners of a 24-hectare parcel of land in Camarines Sur. On August 23, 1984, they filed a complaint (Civil Case No. 84-470) in the Regional Trial Court (RTC) of Camarines Sur against petitioners Rajah Lahuy Mining Company and West Pacific Rich Minerals, Inc. The complaint sought the payment of just compensation or rental as a prerequisite for granting the mining companies authority to conduct mining operations on their land. The petitioners moved to dismiss the complaint on grounds of non-exhaustion of administrative remedies, lack of jurisdiction, res judicata, and prescription. Judge James B. Pajares denied the motion to dismiss, prompting the petitioners to file the instant certiorari and prohibition case.
ISSUE
The core issue is whether the Regional Trial Court has jurisdiction to initially determine and fix the compensation payable to surface owners of land for mining prospecting and exploration activities, or if such jurisdiction is vested in the Bureau of Mines and Geo-Sciences.
RULING
The Supreme Court ruled that the Bureau of Mines and Geo-Sciences, not the Regional Trial Court, has primary jurisdiction to determine the compensation due to surface owners. The legal logic is anchored on the comprehensive statutory framework governing mineral resources. Presidential Decree No. 512, which declares mining operations as matters of public use, explicitly provides the basis and procedures for acquiring surface rights and compensating landowners. It mandates that any compensation for damages to property be guaranteed by a bond posted with the Bureau, and it designates the Director of Mines to fix the bond amount. Crucially, the law states that the Director’s decision may be appealed to the Secretary of Natural Resources, whose decision is final. This establishes a clear administrative remedy.
Furthermore, Presidential Decree No. 463, as amended, and the implementing Consolidated Mines Administrative Order (CMAO) create a specialized and detailed system for resolving disputes over surface rights and compensation, including specific formulas for calculating payments based on royalty shares or land value. The Court emphasized that this specialized administrative machinery is designed for the efficient and expert resolution of such mining-related disputes. Therefore, the RTC acted without jurisdiction in taking cognizance of the complaint in the first instance. To expedite resolution, the Supreme Court ordered that the complaint be indorsed to the Regional Director of the Bureau of Mines and Geo-Sciences for appropriate administrative proceedings. The petition was granted, the RTC order was reversed, and the RTC was permanently enjoined from hearing the civil case.