Carpio vs. Sulu Resources Development Corporation

Decisions and final orders of the Mines Adjudication Board (MAB) are appealable to the Court of Appeals under Rule 43 of the 1997 Rules of Court, as the MAB is a quasi-judicial agency, and Section 79 of RA 7942, which suggests direct appeal to the Supreme Court, is modified by procedural rules and constitutional principles limiting expansions of the Supreme Court's appellate jurisdiction without its consent.

The case arises from a mining dispute under the Philippine Mining Act of 1995 (RA 7942), involving conflicting claims to quarry resources in Antipolo, Rizal, where private landowners like the petitioner assert preferential rights over areas overlapping with corporate mining applications, highlighting tensions between individual property rights and administrative mining allocations by the Department of Environment and Natural Resources (DENR).

• Respondent Sulu Resources Development Corporation applied for MPSA No. MPSA-IV-131 covering areas in Antipolo, Rizal; petitioner Armando C. Carpio, owning landholdings in Cupang and Antipolo, Rizal, filed an opposition claiming overlap and asserting preferential rights to explore and extract quarry resources on his properties; after proceedings, the Panel of Arbitrators of the DENR's Mines and Geosciences Bureau upheld the opposition on September 26, 1996, excluding petitioner's properties from the MPSA; respondent appealed to the MAB, where petitioner moved to dismiss for procedural non-compliance; the MAB set aside the Panel's resolution on June 20, 1997, dismissing the opposition and directing evaluation of the MPSA under RA 7942 and DAO 96-40; petitioner's motion for reconsideration was denied on November 24, 1997; the core factual dispute centered on whether petitioner's properties overlapped with the MPSA area, with the MAB finding no sufficient proof of conflict.

Appeals from MAB decisions should be filed with the Court of Appeals under Rule 43 of the 1997 Rules of Court, as the Supreme Court has rule-making authority under Section 5(5), Article VIII of the Constitution, and the MAB is a quasi-judicial agency; the MAB gravely abused its discretion by disregarding petitioner's proven rights to the land included in the MPSA application; factual findings of the MAB can be reviewed by the CA, especially for grave abuse, consistent with judicial hierarchy and uniform appellate procedures.

The Court of Appeals lacks jurisdiction, as Section 79 of RA 7942 provides for direct appeal by petition for review on certiorari to the Supreme Court within 30 days; adjudication of conflicting mining claims is purely administrative, with MAB findings of fact on overlaps or conflicts being final and executory under RA 7942 and Pearson v. Intermediate Appellate Court; petitioner's challenge is a factual matter already conclusively resolved by the MAB, precluding CA review.

• Procedural Issues: Whether appeals from decisions or final orders of the Mines Adjudication Board (MAB) should be brought directly to the Supreme Court under Section 79 of RA 7942 or to the Court of Appeals under Rule 43 of the 1997 Rules of Court.
• Substantive Issues: N/A.

• Procedural: The Supreme Court granted the petition, reversed the CA's decision and resolution denying jurisdiction, reinstated the CA petition, and ordered the CA to resolve it on the merits; the Court held that Section 79 of RA 7942 is modified by Rule 43, Circular No. 1-91, and related rules, as the MAB is a quasi-judicial agency whose decisions are appealable to the CA on questions of fact, law, or mixed issues, consistent with the Constitution's limits on expanding Supreme Court jurisdiction without consent, the judiciary's rule-making power, and the hierarchy of courts; direct appeals to the Supreme Court are discouraged absent exceptional circumstances.
• Substantive: N/A.

• Hierarchy of Courts — The principle that litigants must seek relief from lower courts before resorting to the Supreme Court, unless exceptional circumstances exist; applied here to require appeals from quasi-judicial agencies like the MAB to proceed first to the CA under Rule 43, avoiding overburdening the Supreme Court and ensuring efficient judicial review.
• Rule-Making Power of the Supreme Court — Under Section 5(5), Article VIII of the Constitution, the Supreme Court has authority to promulgate rules of procedure for all courts and quasi-judicial agencies; invoked to hold that procedural rules like Rule 43 supersede statutory provisions like Section 79 of RA 7942 that expand appellate jurisdiction without consent, treating such expansions as unconstitutional.
• Finality of Administrative Findings — Findings of fact by administrative bodies like the MAB are generally conclusive and binding, but subject to judicial review for grave abuse of discretion via certiorari; distinguished in this case to allow CA review under Rule 43 of MAB decisions, including factual issues, as the CA is equipped to handle such matters unlike the Supreme Court.
• Uniform Procedure for Quasi-Judicial Appeals — Appeals from quasi-judicial agencies must follow Rule 43 to the CA, providing a standardized process; used to classify the MAB as included in the non-exclusive list of agencies under the rule, ensuring consistency and preserving parties' right to appeal without impairing substantive rights.

• "Decisions and final orders of the Mines Adjudication Board (MAB) are appealable to the Court of Appeals under Rule 43 of the 1997 Rules of Court. Although not expressly included in the Rule, the MAB is unquestionably a quasi-judicial agency and stands in the same category as those enumerated in its provisions."
• "Indiscriminate enactment of legislation enlarging the appellate jurisdiction of this Court would unnecessarily burden it."
• "Appeals from decisions of the MAB shall be taken to the CA through petitions for review in accordance with the provisions of Rule 43 of the 1997 Rules of Court."

• Pearson v. Intermediate Appellate Court — Cited by the CA and respondent as precedent for MAB decisions being final and administrative; distinguished by the Supreme Court because it involved review of a trial court's assumption of jurisdiction under Rule 65, not direct appeal of an MAB decision under Rule 43, and affirmed CA jurisdiction over certiorari petitions from administrative actions.
• Fabian v. Desierto — Referenced as controlling precedent striking down Section 27 of RA 6770 for unconstitutionally expanding Supreme Court appellate jurisdiction without consent; applied analogously to invalidate the direct appeal provision in Section 79 of RA 7942 and to mandate Rule 43 appeals to the CA from quasi-judicial bodies like the MAB.
• Sy v. Commission on Settlement of Land Problems — Cited to illustrate invalidation of statutory provisions requiring direct appeals to the Supreme Court from quasi-judicial decisions; used to support treating MAB appeals uniformly under Rule 43, as no reason exists to differentiate from other agencies.
• Metro Construction, Inc. v. Chatham Properties, Inc. — Followed for holding that appeals from quasi-judicial awards, including factual issues, go to the CA under Rule 43, modifying prior statutes; applied to confirm CA jurisdiction over MAB decisions involving facts, law, or mixed questions, and to emphasize the procedural nature of such rules.
• St. Martin Funeral Home v. National Labor Relations Commission — Referenced illustratively for the judicial policy against direct resort to the Supreme Court from administrative agencies, upholding the hierarchy of courts; invoked to discourage bypassing the CA in MAB appeals absent compelling reasons.

• Section 79, Chapter XIII, RA 7942 (Philippine Mining Act of 1995) — Provides that MAB decisions are final and executory, with petitions for review on certiorari filed directly with the Supreme Court within 30 days; held modified by Rule 43, as it unconstitutionally expands Supreme Court jurisdiction without consent under Section 30, Article VI of the Constitution.
• Rule 43, 1997 Rules of Court — Governs appeals from quasi-judicial agencies to the CA via petition for review, covering questions of fact, law, or mixed; applied to include the MAB, providing uniform procedure and allowing review of its decisions, including factual findings challenged for grave abuse.
• Section 5(5), Article VIII, 1987 Constitution — Grants the Supreme Court power to promulgate rules of procedure for courts and quasi-judicial bodies; relied upon to affirm Rule 43's supremacy over conflicting statutes like Section 79 of RA 7942.
• Section 30, Article VI, 1987 Constitution — Prohibits laws increasing Supreme Court appellate jurisdiction without its advice and consent; used to declare Section 79 of RA 7942 unconstitutional in effect for direct appeals, redirecting them to the CA.
• Section 9, BP Blg. 129 as amended by RA 7902 — Defines CA's exclusive appellate jurisdiction over quasi-judicial agencies; cited to expand CA's role in reviewing factual issues from bodies like the MAB.