Scott Consultants & Resource Development Corporation v. Court of Appeals

Summary

This commercial law dispute involved competing mining rights and access to mining claims in Rodriguez, Rizal. Scott Consultants sought to enforce mining exploration agreements but was blocked from accessing mining sites through routes constructed by Philippine Rock Products. The Supreme Court affirmed that Scott Consultants lacked valid mining rights due to an expired option agreement and improper termination of existing operator agreements, which fell under Bureau of Mines' exclusive jurisdiction. While Scott Consultants could not use privately-constructed access routes without proper easement rights, the Court deleted all damage awards against it for lack of sufficient proof, emphasizing that actual damages must be duly proven under Article 2199 of the Civil Code and that exemplary damages require entitlement to compensatory damages as prerequisite.