Maneclang v. Maza
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for quieting of title over a fishpond located within their titled lands and for the annulment of Resolutions Nos. 38 and 95 of the Municipal Council of Bugallon, Pangasinan. The body of water was found to be a creek, a tributary of the Agno River, and thus public in nature. Procedural History: The trial court dismissed the complaint, holding that the body of water was a public creek not subject to private appropriation and that 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 sought a review on certiorari of the appellate court's decision. Subsequently, the parties submitted a Compromise Agreement to amicably settle the case, praying for a judgment recognizing petitioners' ownership over the fishpond. The Court found the Compromise Agreement to be contrary to law and public policy.
Issue(s)
Whether a compromise agreement adjudicating ownership of a creek, which is a property of the public domain, is valid. Whether the conversion of a creek into a fishpond alters its nature as a public water. Whether the Municipal Council of Bugallon acted within its legislative powers in passing resolutions concerning the municipal waters and whether petitioners were deprived of due process.
Ruling
The Court resolved to set aside the Compromise Agreement, declare it null and void for being contrary to law and public policy, and dismiss the petition for lack of merit.
Ratio Decidendi
On the validity of the compromise agreement: The Court held that the Compromise Agreement, which sought to adjudicate ownership of the disputed fishpond to the petitioners, was null and void. This is because the body of water was clearly found by the lower and appellate courts to be a creek, a tributary of the Agno River. As established in jurisprudence, a creek is a property belonging to the public domain and is not susceptible to private appropriation or acquisitive prescription. Therefore, any agreement attempting to grant private ownership over it is contrary to law and public policy. On the alteration of the creek's nature: The Court clarified that neither the construction of irrigation dikes by the National Irrigation Administration, which prevented water from flowing in and out, nor the conversion of the creek into a fishpond, alters its fundamental nature as a property of the public domain. The inherent character of the water body as a public resource remains unchanged regardless of human intervention or its current use. On the powers of the Municipal Council and due process: The Court affirmed that the Municipality of Bugallon, through its municipal council, was clothed with the authority to pass resolutions concerning its municipal waters. The resolutions ordering an ocular inspection and authorizing public bidding for the lease of fisheries were within the council's legislative powers. Furthermore, the Court found that petitioners were not deprived of their right to due process, as the mere publication of the notice of the public bidding sufficed as constructive notice to the whole world, fulfilling the requirements for such proceedings.
Main Doctrine
A compromise agreement that adjudicates ownership of a creek, which is a property of the public domain 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 does not alter its nature as public water.