Twin Peaks Mining Association v Navarro (Natural Resourcesj

TWIN PEAKS MINING ASSOCIATION v NAVARRO 

G.R. No. L-49835 

December 18, 1979  

FACTS:  

On September 1, 1978, Philex Mining Corporation filed in the Court of First Instance of Rizal, Pasig Branch 11 a complaint against the Twin Peaks Mining Association and its four partners. It prayed for a judgment declaring as valid and binding on Twin Peaks the two agreements dated May 22, 1970 and June 25, 1971 for the exploration, operation and exploitation of two hundred ninety lode mineral claims located at Tuba, Benguet. The agreements were entered into between Philex and the late geodetic engineer, Andres K. Espiritu, who represented himself to be the general manager of Twin Peaks but who was not a partner thereof.  

The firm and its four partners filed a motion to dismiss on the grounds of lack of jurisdiction and cause of action.  

DECISION OF LOWER COURTS: * Trial court: denied the motion to dismiss. It sustained plaintiff's stand that the validity of the said mining contracts is a justiciable question that should be resolved by the courts and that the complaint states a cause of action against the defendants.  

ISSUE: Is the trial court vested with jurisdiction over the case?  

HELD: NO.  

the trial court has no jurisdiction over the case and that the issue of whether the two contracts are valid falls within the exclusive competence of the Bureau of Mines as clearly indicated in section 7(c) of Presidential Decree No. 1281 which took effect on January 16, 1978.  

That decree revised Commonwealth Act No. 136 (the law creating the Bureau of Mines) for the purpose of making that agency "a more potent and effective arm of the Government in the administration and disposition of our mineral resources and responsive to the needs of the Filipino people, in general, and the mining industry, in particular. "  

And it is noteworthy that the trend is to make the adjudication of mining cases a purely administrative matter. Thus, it cannot escape notice that under section 61 of the Mining Law, Commonwealth Act No. 137, as amended by Republic Acts Nos. 746 and 4388, appeals from the decision of the Secretary of Agriculture and Natural Resources (now Minister of Natural Resources) on conflicts and disputes arising out of mining locations may be made to the Court of Appeals or the Supreme Court, as the case may be.