Benguet Corporation vs Oscar Leviste GR No. L-65021

Benguet Corporation vs Hon. Oscar L. Leviste

GR No. L-65021                                                       November 21,1991

Facts:

Helen Dizon-Reyes (private-respondent), "Helen" for brevity, filed a case before RTC-Quezon City docketed as Civil Case No. Q-30171 alleging ownership over 11 mining claims and seeking the cancellation of the Operations Agreement entered into by Dizon Mines and Benguet Corporation.

The antecedent of the facts are as follows:

1. Helen appointed his father Celestino M. Dizon, "Celestino" for brevity, by virtue of an SPA to be her lawful representative to transfer, assign and dispose her 11 mining claims.
2. Celestino, entered into an Agreement with Dizon Mine granting Dizon Mine to explore, develop, exploit and operate 57 mining claims, which includes the 11 mining claims of Helen.
3. Helen and other claim-owners executed a Deed of Ratification of Assignment thereby confirming, transferring, conveying and assigning Dizon Mines to possess, occupy, explore, develop and operate the mining claims.
4. Helen thereafter revoked the SPA. However despite this revocation, Dizon Mines and Benguet Corp. entered into an Operation Agreement transferring to Benguet Corp. the possession of the 57 mining claims.
5. Helen now claims that the Operation Agreement lacks legal basis due to her revocation of the SPA.
6. Benguet Corp. moved for the Dismissal of the case based on different grounds, the cardinal ground which is the focus of this case is that the RTC has no jurisdiction over the subject matter and nature of the action and the venue was improperly laid.

Issue:

Whether or not RTC has jurisdiction over cancellation of mining contracts.

Ruling:

No, Section 7 of PD 1281 provides:

Section 7. In addition to its regulatory and adjudicative functions over companies, partnership or persons engaged in mining exploration, development and exploitation, the Bureau of Mines shall have original and exclusive jurisdiction to hear and decide cases involving:

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(c) cancellation and/or enforcement of mining contracts due to refusal of the claim-owner/operator  to abide the terms and conditions thereof.

The court ruled that the subject agreement of this case is a mining contract and Helen is seeking for its nullity, does not wish to abide the terms and condition of the said contract, thereby the said case is within the jurisdiction of the Bureau of Mines by virtue of Section 7 of PD 1281.