SANTA ROSA MINING COMPANY VS. JOSE LEIDO, JR., digested
GR # L-49109 December 1, 1987 (Law on Natural Resources)
FACTS: 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 of application within one (1) year from the approval of the Decree. To protect its rights, petitioner Santa Rosa Mining Company files a special civil action for certiorari and prohibition confronting the said Decree as unconstitutional in that it amounts to a deprivation of property without due process of law. Subsequently, three (3) days after, petitioner filed a mining lease application, but “under protest”, with a reservation that it is not waiving its rights over its mining claims until the validity of the Decree shall have been passed upon by the Court.
The respondents allege that petitioner has no standing to file the instant petition and question the Decree as it failed to fully exhaust administrative remedies.
ISSUE: Whether or not Presidential Decree No. 1214 is constitutional.
HELD: Yes, Presidential Decree No. 1214 is constitutional, even assuming arguendo that petitioners was not bound to exhaust administrative remedies for its mining claims to be valid in the outset. It is a valid exercise of the sovereign power of the State, as owner, over the lands of the public domain, of which petitioner’s mining claims still form a part. Moreover, Presidential Decree No. 1214 is in accord with Sec. 8, Art XIV of the 1937 Constitution.
FACTS: 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 of application within one (1) year from the approval of the Decree. To protect its rights, petitioner Santa Rosa Mining Company files a special civil action for certiorari and prohibition confronting the said Decree as unconstitutional in that it amounts to a deprivation of property without due process of law. Subsequently, three (3) days after, petitioner filed a mining lease application, but “under protest”, with a reservation that it is not waiving its rights over its mining claims until the validity of the Decree shall have been passed upon by the Court.
The respondents allege that petitioner has no standing to file the instant petition and question the Decree as it failed to fully exhaust administrative remedies.
ISSUE: Whether or not Presidential Decree No. 1214 is constitutional.
HELD: Yes, Presidential Decree No. 1214 is constitutional, even assuming arguendo that petitioners was not bound to exhaust administrative remedies for its mining claims to be valid in the outset. It is a valid exercise of the sovereign power of the State, as owner, over the lands of the public domain, of which petitioner’s mining claims still form a part. Moreover, Presidential Decree No. 1214 is in accord with Sec. 8, Art XIV of the 1937 Constitution.
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