The Supreme Court ruled that Regional Trial Courts (RTCs) lack jurisdiction over boundary disputes between provinces; such matters are for the provincial boards. Additionally, mining permits issued by a governor, instead of the Provincial Mining Regulatory Board, are invalid. This decision clarifies the proper channels for resolving territorial disputes and the correct authority for issuing mining permits, affecting how mining rights are asserted within logging concession areas.

Navigating Boundaries and Permits: Whose Land Is It Anyway?

In this case, Leonora P. Calanza and others, the petitioners, sought to extract gold within an area claimed by the Paper Industries Corporation of the Philippines (PICOP) as part of its logging concession. Petitioners, armed with small-scale mining permits issued by the governor of Davao Oriental, faced PICOP’s refusal to allow them entry, arguing that the area fell under their Timber License Agreements (TLAs). This conflict brought to the forefront questions of territorial jurisdiction and the validity of mining permits issued outside the legally prescribed authority. The central question revolves around whether the RTC correctly assumed jurisdiction over a boundary dispute and whether a governor can legally issue mining permits within areas covered by existing TLAs.

The heart of the matter rests on Section 118 of the Local Government Code, which clearly outlines the procedure for settling boundary disputes. It stipulates that disputes involving municipalities or cities of different provinces should be jointly referred to the respective sanggunians (provincial boards) for settlement. In case of failure to reach an amicable agreement, the sanggunians must issue a certification, after which the dispute undergoes formal trial within the sanggunian. Any dissatisfied party can then elevate the sanggunian’s decision to the Regional Trial Court (RTC) for judicial review.

Sec. 118. Jurisdictional Responsibility for Settlement of Boundary Dispute. – Boundary disputes between and among local government units shall, as much as possible, be settled amicably.  To this end:

(c) Boundary disputes involving municipalities or component cities of different provinces shall be jointly referred for settlement to the sanggunians of the provinces concerned.

In this case, the RTC took it upon itself to determine the location of the mining area, effectively resolving a boundary dispute without the proper procedure. The Supreme Court noted that the RTC could not exercise appellate jurisdiction as there was no prior decision from the involved sanggunians. Nor could it assume original jurisdiction, as the power to resolve such disputes initially lies with the provincial boards. This jurisdictional overreach rendered the RTC’s decision null and void, emphasizing the principle that a judgment from a court lacking jurisdiction is without legal effect.

Adding another layer of complexity, the validity of the mining permits issued by the governor was questioned. The People’s Small-Scale Mining Act of 1991 (Republic Act No. 7076) vests the authority to approve mining permits and contracts in the Provincial Mining Regulatory Board (PMRB), not the governor. The PMRB, composed of representatives from various sectors including the DENR, small-scale mining, big-scale mining, and environmental groups, is tasked with ensuring compliance with mining regulations.

Since the permits were issued by the governor of Davao del Norte, an authority not legally empowered to do so under RA 7076, they were deemed invalid. This underlines a crucial aspect of administrative law: that public officials can only exercise powers explicitly granted to them by law. The permits’ invalidity further justified PICOP’s refusal to allow the petitioners access to the disputed mining area. Thus, a convergence of jurisdictional and administrative errors led to the dismissal of the petitioners’ complaint.

The Supreme Court emphasized the stringent adherence to jurisdictional and procedural requirements in settling boundary disputes and issuing mining permits. The rightful jurisdiction over boundary disputes resides in the concerned sanggunians and any aggrieved party must then follow the appropriate channels of appeal to the RTC. Moreover, under the People’s Small-Scale Mining Act, only the Provincial Mining Regulatory Board can issue valid permits for small-scale mining operations, reinforcing checks and balances in the extraction of resources within the Philippines.

FAQs

What was the key issue in this case?	The central issue was whether the Regional Trial Court (RTC) had jurisdiction to resolve a boundary dispute between two provinces and whether mining permits issued by the governor were valid.
Who is authorized to resolve boundary disputes between provinces?	Under Section 118 of the Local Government Code, boundary disputes between provinces must first be referred to the sanggunians (provincial boards) of the provinces involved for resolution.
Can the RTC decide a boundary dispute directly?	No, the RTC can only exercise appellate jurisdiction over boundary disputes after the sanggunians have made a decision, and such decision is appealed.
Who has the authority to issue small-scale mining permits?	The People’s Small-Scale Mining Act of 1991 (RA 7076) grants the Provincial Mining Regulatory Board (PMRB) the authority to issue small-scale mining permits, not the governor.
What happens if a court makes a decision without jurisdiction?	A decision rendered by a court without jurisdiction is null and void, creating no rights and producing no legal effect.
What law governs the issuance of mining permits in this case?	The People’s Small-Scale Mining Act of 1991 (RA 7076) is the governing law, which specifies the PMRB as the issuing authority.
What was PICOP’s argument in denying entry to the petitioners?	PICOP argued that the mining area fell within its logging concession area under Timber License Agreements (TLAs) and that the mining permits were invalidly issued.
What was the effect of the RTC’s decision on the mining permits?	The RTC’s decision to enforce permits issued by a non-authorized person was itself void due to lack of jurisdiction over the main issue of the location of territorial boundaries.

This case emphasizes the importance of adhering to established legal procedures for resolving jurisdictional disputes and issuing permits. It serves as a reminder that any action taken outside the bounds of legal authority is void and without effect. In this context, protecting existing logging concessions relies significantly on enforcing strict compliance by those entering concession land to engage in resource extraction.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Leonora P. Calanza, et al. vs. Paper Industries Corporation of the Philippines (PICOP), et al., G.R. No. 146622, April 24, 2009