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CARPIO v SRDC

FACTS:

1. SRDC filed a petition for Mines Production Sharing Agreement


(MPSA) covering certain areas in Rizal.
2. Carpio filed an opposition/adverse claim thereto alleging that his
landholdings in Antipolo, Rizal will be covered by SRDAs claim,
thus he enjoys a preferential right to explore and extract the
quarry resources in his property.
3. The Panel of Arbitrators from the Mines and Geo-Sciences Bureau
of the DENR rendered a Resolution upholding Carpios
opposition/adverse claims. It ordered that the area covering
Carpios landholding be excluded as subject to mining locations.
4. SRDA appealed the Resolution to the Mines Adjudication Board.
Carpio on the other hand filed a MTD on the ground of SRDAs
failure to comply with the requirements of the New Mining Acts
Implementing Rules and Regulations.
5. The Mines Adjudication Board rendered a decision setting aside
the adverse claim/opposition of Carpio. The Agreement of SRDA
should be given due process.
6. A MFR was filed by Carpio but was denied by the Board.
7. Upon appeal, CA ruled that it did not have jurisdiction to review
the Decision of the Mines Adjudication Board. The adjudication of
mining claims is completely administrative in nature. Under RA
972 (Philippine Mining Act), the settlement of disputes involving
mining areas shall pertain exclusively to a Panel of Arbitrators of
the DENR whose decision are appealable to the MAB. The
findings of fact by the MAB as well as its decision or order shall
be final and executory.
8. Hence, this petition.

ISSUE: W/N appeals from the decision and final order of the
MAB should be made directly to the SC or to the CA?

HELD: Appeals should first be made to the CA.

1. In the case at bar, Carpio went to the CA through a Petition for


Review on Certiorari under Rule 43 seeking a reversal of the MAB
decision.
2. There is a difference between the powers granted by law to an
administrative agency which nature of power is purely
administrative. These powers should be distinguished from
litigant disagreements or controversies that are civil or
contractual in nature, which may be adjudicated only by the
Courts of Justice. While the findings of fact of the MAB, which
exercises appellate jurisdiction over decisions or orders of the
panel of arbitrators are final and executory, petitions for
certiorari may be filed with the appropriate court.
3. Appeals from judgment and final orders of quasi judicial agency
are now required to be brought to the CA, under Rule 43. This
rule was adopted to provide a uniform rule of appellate
procedure from quasi-judicial agencies.
o A case struck down Section 27 of RA 6770 as
unconstitutional because it had broadened the appellate
jurisdiction of the SC without its consent. It provides that
all administrative decisions of the Office of the
Ombudsman may be appealed to the SC.
4. A petition for review with the CA is proper because it involves
factual controversies which are usually involved in administrative
actions. CA is prepared to handle such issues because unlike the
SC, it is mandated to rule on questions of fact. The review of the
decision and order of administrative agencies included questions
of fact and law.
5. Legal footings authorizing a review of the MAB under Rule 43:
a. Section 30, Article 6 of the 1987 Consti: no law shall be
passed increasing the appellate jurisdiction of the SC without
its advice and consent.
b. Where the SC in the exercise of its rule-making power,
transfers to the CA pending cases involving a review of a
quasi-judicial bodys decisions, the transfer is merely
procedural and does not impair vested rights of the parties.
The aggrieved partys right to appeal is procedure.
c. Rule 43 of the Civil Procedure.
o Appeals from judgments of quasi-judicial agencies are
required to be brought to the CA.
o Quasi-judicial agency has been defined as an organ of
government, other than a court or legislature which affects
the rights of private parties through either adjudication or
rule making.
d. Factual controversies are involved in decision of quasi-judicial
bodies and the CA is tasked to resolve questions of fact.
Under Rule 43, appeal from quasi judicial agency involves
questions of fact, of law or mixed questions of fact and law.
e. Doctrine of exhaustion of remedies.
6. In the case at bar, MAB is a quasi judicial agency.