Santa Rosa Mining Company, Inc. v Leido (Natural Resources)

SANTA ROSA MINING COMPANY, INC. v LEIDO (DENR) 

G.R. No. L-49109 

December 1, 1987  

FACTS:  

Petitioner Santa Rosa Mining Company, Inc. (petitioner, for short) is a mining corporation duly organized and existing under the laws of the Philippines. It alleges that it is the holder of fifty (50) valid mining claims situated in Jose Panganiban, Camarines Norte, acquired under the provisions of the Act of the U.S. Congress dated 1 July 1902 (Philippine Bill of 1902, for short).  

On 14 October 1977, Presidential Decree No. 1214 was issued, requiring holders of subsisting and valid patentable mining claims located under the provisions of the Philippine Bill of 1902 to file a mining lease application within one (1) year from the approval of the Decree. Petitioner accordingly filed a mining lease application, but "under protest," on 13 October 1978, with a reservation annotated on the back of its application that it is not waiving its rights over its mining claims until the validity of Presidential Decree No. 1214 shall have been passed upon by this Court.  

Petitioner avers that its fifty (50) mining claims had already been declared as its own private and exclusive property in final judgments rendered by the Court of First Instance of Camarines Norte (CFI, for short) in land registration proceedings initiated by third persons, such as, a September 1951 land title application by a certain Gervacio Liwanag, where the Director of Mines opposed the grant of said application because herein petitioner, according to him (Director of Mines), had already located and perfected its mining claims over the area applied for.  

ISSUES: (1) Whether Santa Rosa already had a vested right over its mining claims even before Presidential Decree No. 1214, following the rulings in McDaniel v. Apacible and Gold Creek Mining Corp. v. Rodriguez (2) whether or not Presidential Decree No. 1214 is constitutional  

HELD: (1) NO.