Semirara Coal Corporation (Now Semirara Mining Corporation) v. Hgl Development Corporation

Summary

Semirara Mining Corporation encroached upon land covered by HGL Development Corporation's Forest Land Grazing Lease Agreement, constructing facilities and conducting mining operations without permission, severely damaging the grazing business. Despite DENR's cancellation of HGL's lease (which was being contested in separate proceedings), the courts found HGL retained possessory rights until the lease's 2009 expiration. The Supreme Court affirmed the issuance of a preliminary mandatory injunction ordering Semirara to restore possession to HGL, ruling that lawful possessors under Article 539 of the Civil Code are entitled to protection from unauthorized disturbance. The decision established that preliminary mandatory injunctions are appropriate remedies for possession disputes and that mining concessions do not automatically override existing land use agreements when encroachment occurs outside the scope of the concession's legal authority.