Maneclang v. Maza
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for quieting of title over a fishpond and annulment of Resolutions Nos. 38 and 95 of the Municipal Council of Bugallon, Pangasinan. The fishpond was located within their titled properties. The body of water was found to be a creek, a tributary of the Agno River, and thus public in nature, not subject to private appropriation. Procedural History: The trial court dismissed the complaint, holding that the body of water was a public creek and the municipal council acted within its legislative powers in passing the resolutions. The Intermediate Appellate Court affirmed the trial court's decision. The Petition: Petitioners filed a petition for review on certiorari. Subsequently, the parties manifested their desire to amicably settle the case through a Compromise Agreement, recognizing petitioners' ownership over the fishpond, citing that the National Irrigation Administration had built a dike around the land, preventing water flow, and that pursuing the case would not benefit the parties but rather the municipality if ownership was recognized in favor of petitioners.
Issue(s)
Whether the Compromise Agreement recognizing petitioners' ownership over the fishpond, originally a creek, is valid. Whether the Municipal Council of Bugallon acted within its authority in passing resolutions concerning the municipal waters and authorizing public bidding for the lease of fisheries; and whether petitioners were deprived of due process.
Ruling
The Court set aside the Compromise Agreement and declared it null and void for being contrary to law and public policy. The Court dismissed the petition for lack of merit.
Ratio Decidendi
On the validity of the Compromise Agreement: The Court found the Compromise Agreement null and void and of no legal effect. The agreement sought to adjudicate ownership of the fishpond, which was clearly found by the lower and appellate courts to be originally a creek forming a tributary of the Agno River. As established in jurisprudence, a creek is a property belonging to the public domain, not susceptible to private appropriation or acquisitive prescription. The Court reiterated that public waters cannot be registered under the Torrens System in the name of any individual. Furthermore, the Court held that neither the construction of irrigation dikes by the National Irrigation Administration, which prevented water flow, nor the conversion of the creek into a fishpond, alters its nature as a property of the public domain. Therefore, the Compromise Agreement was contrary to law and public policy. On the authority of the Municipal Council and due process: The Court affirmed that the finding that the subject body of water is a creek belonging to the public domain is a factual determination binding upon the Supreme Court. The Municipality of Bugallon, acting through its municipal council, was clothed with the authority to pass the resolutions concerning its municipal waters. The Court also held that petitioners were not deprived of their right to due process, as the mere publication of the notice of the public bidding suffices as constructive notice to the whole world.
Main Doctrine
A compromise agreement that seeks to adjudicate ownership of a body of water found to be a creek, which is part of the public domain and not susceptible to private appropriation, is null and void as it is contrary to law and public policy. The conversion of a creek into a fishpond or the construction of dikes does not alter its nature as public property.