Fred M. Harden v. Benguet Consolidated Mining Company

Summary

Minority shareholders of Balatoc Mining Company challenged the validity of a development contract and stock issuance to Benguet Consolidated Mining Company, claiming violation of laws prohibiting mining corporations from holding interests in other mining corporations. The Supreme Court affirmed dismissal of the complaint, holding that statutory prohibitions against inter-corporate holdings in mining companies serve public policy purposes and can only be enforced by the Government through criminal prosecution or quo warranto proceedings, not through private civil actions. The Court found no civil wrong against plaintiffs and noted that special statutory remedies preclude application of general Civil Code provisions regarding illegal contracts. The decision establishes that private parties cannot challenge corporate transactions that violate regulatory prohibitions designed for public policy enforcement, leaving such enforcement exclusively to government authorities.