Mateo v. Moreno
REITERATIONFacts
1. The Antecedents: Residents of Guiguinto, Bulacan, complained that Sapang Cabay, a public navigable stream, had been obstructed by dikes and dams, effectively converted into fishponds. This obstruction prevented public use for fishing, gathering fuel, and caused flooding in surrounding areas during heavy rains. Historical accounts from elderly residents indicated that the creek was previously navigable by boats and used for various public purposes before its closure. 2. Procedural History: The complaint was forwarded to the Secretary of Public Works and Communications, who initiated an investigation under Republic Act No. 2056. Following the investigation, the Secretary ordered Cenon Mateo, the current owner of the property containing the creek, to remove the dikes and dams. Mateo's motion for reconsideration was denied. He then filed a petition for injunction with the Court of First Instance of Manila, which dismissed his petition. The case was elevated to the Court of Appeals and subsequently certified to the Supreme Court due to the constitutional questions involved. 3. The Petition: The petitioner-appellant, Cenon Mateo, raised six errors, primarily challenging the jurisdiction of the Secretary of Public Works and Communications to determine the nature of Sapang Cabay and arguing that Republic Act No. 2056 is unconstitutional for improperly delegating judicial power and depriving individuals of property without due process. He also contended that the Act was inapplicable, that Sapang Cabay was not a public navigable waterway, and that his Torrens title should have superseded the administrative findings. The petition sought a writ of injunction to prevent the enforcement of the Secretary's decision.
Issue(s)
Whether Republic Act No. 2056 is unconstitutional for being an undue delegation of judicial power to the Secretary of Public Works and Communications. Whether the findings of the Secretary of Public Works and Communications that Sapang Cabay is a public navigable stream are conclusive upon the courts. Whether a Torrens Certificate of Title precludes the government from identifying a navigable stream within the registered property and ordering the removal of obstructions therein.
Ruling
The decision of the Court of First Instance of Manila dismissing the petition for injunction is affirmed. The Secretary of Public Works and Communications acted within his jurisdiction and authority in ordering the removal of the dikes and dams.
Ratio Decidendi
On Issue 1: The Supreme Court reiterated its ruling in Lovina v. Moreno, holding that Republic Act No. 2056 is constitutional. The statute does not constitute an unlawful delegation of judicial power as the Secretary of Public Works and Communications is merely performing administrative functions related to the regulation of public waters. The power to order the removal of obstructions in navigable waters is an exercise of police power intended to protect public interest in navigation and drainage. Consequently, the delegation of authority to an administrative officer to determine facts and enforce the law does not violate the principle of separation of powers. The Court found no basis to depart from this established precedent. On Issue 2: The Court applied the 'substantial evidence' rule, stating that administrative findings of fact are conclusive as long as they are supported by such relevant evidence as a reasonable mind might accept as adequate. In this case, the evidence was more than merely substantial, featuring testimony from several elderly residents (ages 64 to 79) who confirmed that Sapang Cabay was used for fishing and navigation via boats (bancas) before its closure. Ocular inspections revealed visible traces of the creek's path and the presence of man-made canals used to divert water. The Court emphasized that it is not its function to reassess the preponderance of evidence but merely to verify if the administrative record supports the conclusion. Because the record provided ample evidence of the creek's historical navigability and the resulting flooding caused by the dikes, the SPWC's findings were upheld. On Issue 3: The Court ruled that a Torrens Certificate of Title does not change the public character of a navigable stream. Under Section 39 of Act No. 496, certain public easements and rights are considered inherent exceptions to the indefeasibility of a title even if they are not noted on the certificate. Ownership of a navigable stream or its bed is not subject to acquisitive prescription, meaning no amount of time or registration can convert a part of the public domain into private property. The fact that the petitioner or his predecessors-in-interest managed to obtain a title covering the area does not strip the stream of its public nature. Therefore, the SPWC has the legal authority to order the removal of dikes that encroach upon such public waters despite the existence of a title.
Main Doctrine
The constitutionality of Republic Act No. 2056, which grants the Secretary of Public Works and Communications jurisdiction to investigate and order the removal of obstructions in public navigable streams, has been upheld. Findings of fact by the Secretary, if supported by substantial evidence, are conclusive and not subject to judicial re-assessment, absent illegality, fraud, or grave abuse of discretion. A Torrens title does not preclude a finding that a portion of the property is a public navigable waterway.