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.