Facts:
1. **Background**: Dr. Lourdes S. Pascual, Dr. Pedro De la Concha, Alejandro De La Concha, and Rufo De Guzman were granted permission to prospect for marble deposits in the Biak-na-Bato mountain range, San Miguel, Bulacan. They discovered high-quality marble deposits in Mount Mabio.
2. **License Issuance**: After complying with multiple conditions, the Bureau of Mines issued Quarry License No. 33 (QLP No. 33) to the petitioners, allowing them to exploit the marble deposits.
3. **License Cancellation**: Ernesto R. Maceda, then Minister of DENR, cancelled QLP No. 33 via a letter dated September 6, 1986, claiming that the license was issued in contravention of existing laws.
4. **Amended Petition**: Petitioners filed an original petition challenging the cancellation, followed by an amended petition on August 21, 1991.
5. **Injunction**: On February 28, 1992, the court issued a preliminary injunction following the petitioners filing a bond of P1,000,000.
6. **Trial Court Decision**: The RTC rendered a decision on September 27, 1996, ruling that the cancellation of the license was a deprivation of property without due process and thus reinstated the license.
7. **Appeal to CA**: The petitioners (Government) appealed to the Court of Appeals, questioning the license validity under PD 463 and Proclamation No. 84’s implications.
8. **CA Ruling**: The CA upheld the RTC decision entirely, arguing the quarry license was legally granted and upholding the non-impairment of contracts and due process.
9. **Petition to Supreme Court**: The Government then petitioned for the review of the CA’s decision, leading to this Supreme Court case.
Issues:
1. **Validity of QLP No. 33**: Whether QLP No. 33 issued to respondents violated Section 69 of PD 463.
2. **Validity of Proclamation No. 84**: Whether Proclamation No. 84 issued by President Corazon Aquino is valid and whether it is an ex post facto law.
Court’s Decision:
1. **Validity of License QLP No. 33**: The Court found the license violated Section 69 of PD 463, as it covered 330.3062 hectares—far exceeding the 100-hectare limit per province. The Court dismissed respondents’ arguments that the area was covered by four applications of 81 hectares each and emphasized that QLP No. 33 was issued solely to Rosemoor Mining as one entity.
2. **Validity of Proclamation No. 84**: The Court ruled Proclamation No. 84 valid, indicating the President exercised legitimate power to revert the land to national park status in the national interest. It also held that the proclamation did not violate the non-impairment clause, as the respondents’ license was a privilege, not a vested property right, and could be revoked by the State in the exercise of its police power.
3. **Ex Post Facto and Bill of Attainder**: The Court dismissed the claims that Proclamation No. 84 was an ex post facto law or a bill of attainder, noting that it did not impose any criminal penalty or punishment without trial.
Doctrine:
1. **Regalian Doctrine**: The State retains ownership of all natural resources, and licenses pertaining to these resources are privileges that do not vest permanent property rights in the holders.
2. **Due Process and Non-Impairment Clause**: The State can revoke privileges such as mining licenses without offending the due process and non-impairment clauses if done in public interest and through due executive procedures.
3. **Police Power of the State**: The Court reiterated that the exercise of police power includes the revocation of previously granted privileges when public interest demands.
Class Notes:
1. **Mining Laws**: Examine specific restrictions under PD 463 concerning the maximum area for quarry licenses.
2. **Constitutional Compliance**: Understand the transition from the 1973 to the 1987 Constitution and how it impacts natural resource exploitation.
3. **Police Power vs. Non-Impairment**: Distinguish between vested property rights and state-granted privileges, emphasizing scenarios where state interests override contractual protections.
4. **Proclamation and Executive Orders**: Assess how executive powers are exercised in issuing proclamations affecting national interests.
Historical Background:
This case unfolds during a time of significant constitutional transition in the Philippines, from the 1973 to the 1987 Constitution. It highlights evolving policies on natural resource management, emphasizing state control over exploitation rights. The context also includes the political shift following the People Power Revolution, which propelled Corazon Aquino into power and led to significant changes in governance and policy directions. The case reflects the balance of private investments in natural resources with the state’s overarching control for public welfare and environmental protection.
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