Miners Association of the Philippines v.

Factoran
G.R. No. 98332, January 16, 1995

Doctrine:
The power of administrative officials to promulgate rules and regulations in the
implementation of a statue is necessarily limited only to carrying into effect what is
provided in the legislative enactment.

Facts:

President Corazon Aquino promulgated Executive Order No. 211 which prescribes the
interim procedures in the processing and approval of applications for the exploration,
development, and utilization of minerals pursuant to Sec. 2 Art. XII of the 1987
Constitution. President Aquino likewise promulgated Executive Order No. 279
authorizing the DENR Secretary to negotiate and conclude joint venture, co-production,
or product sharing agreements and those involving technical and financial assistance by
foreign-owned corporations. Pursuant to the provisions, the DENR Secretary issued
DENR Administrative Order Nos 57 & 82.
The implementation by the DENR of the Administrative Orders No. 57 & 82 after their
effectivity dates compelled the petitioner Miners Association of the Philippines to file the
instant petition assailing their validity and constitutionality. Petitioner claims that the
respondent Secretary of DENR acted in excess of his rule making power in issuing the
administrative orders and that both orders violate the nonimpairment of contract for
unduly pretermination of mining leases and mining agreements. A Temporary
Restraining Order was issued by the court enjoining the enforcement of the
administrative orders.

Issues:

1. WON respondent acted in excess of his rule making power

2. WON Administrative Orders No. 57 & 82 is valid

Ruling:
1. NO. Sec. 6 of the Executive Order No. 279 specifically authorizes said official to
promulgate supplementary rules and regulations. The issuance of the respondent
of the Administrative Order Nos. 57 & 82 is done in accordance with the
Executive Order No. 279 which carries out the mandate of Sec. 2 Art. XII

2. YES. Administrative Order No. 57 & 82 is valid. The issuance of the Executive
Order No. 279 validly modified or altered the terms and conditions of mining
leases and agreements under the Presidential Decree No. 463. The Presidential
Decree No. 463 provides the old system of exploration, development, and
utilization of natural resources through license, concession or lease which has
been disallowed by Sec. 2 Art. XII of the Constitution. The passage of Executive
Order No. 279 provided legal basis for the DENR Secretary to carry in to effect
the mandate of the constitutional provision. The questioned administrative orders
 are reasonably directed to the accomplishment of the purpose of the provision,
thus, the validity and the constitutionality of Administrative Order Nos. 57 & 82
must be sustained.

The petition is DISMISSED for lack of merit and the Temporary Restraining Order is
hereby lifted.