Meneses v. Commonwealth
REITERATIONFacts
The Antecedents: The Government of the Commonwealth of the Philippines (plaintiff) filed a civil case against Ramon Meneses (defendant) in the Court of First Instance of Bulacan. The government sought to compel Meneses to remove a fish weir constructed in what the government claimed was a portion of the Bambang River in Bulacan. Meneses contended that the weir was built on his private property and had always been there, not in the river. Procedural History: The Court of First Instance ruled in favor of Meneses, finding that the fish weir was constructed on private property and not in the Bambang River. The Government appealed this decision to the Court of Appeals. The Court of Appeals reversed the lower court's decision, declaring that the fish weir was indeed constructed in a portion of the riverbed of the Bambang River, which is of public dominion and open to navigation and public use. Meneses then filed the present petition for certiorari with the Supreme Court. The Petition: Meneses filed a petition for certiorari with the Supreme Court, attributing two errors to the Court of Appeals: (I) in holding that the fish weir was constructed on land formed by the successive accumulation of river deposits from the Bambang River; and (II) in failing to declare that Meneses is the owner of the land where the fish weir is constructed. The Supreme Court, in a certiorari proceeding, is limited to reviewing errors of law and not of fact.
Issue(s)
Whether the fish weir was constructed on a portion of the Bambang Riverbed. Whether the Bambang Riverbed, where the fish weir is located, is of public dominion and thus not subject to private ownership or prescription.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The fish weir was declared to be constructed in a portion of the Bambang Riverbed, which is of public dominion and therefore not susceptible to private appropriation or prescription. The petition for certiorari was denied, with costs against the petitioner.
Ratio Decidendi
On Issue 1: The Supreme Court held that the fish weir was constructed in a portion of the Bambang Riverbed. The Court emphasized that in a certiorari proceeding, it is not its function to examine the facts for the purpose of review. The facts declared by the Court of Appeals, which were that the fish weir was constructed in a part of the Bambang River's course, that the river is navigable for public use (albeit with difficulty), and that the weir covered a significant portion of the riverbed, were taken as certain. The Court noted that the weir had been in the exclusive possession of the petitioner's predecessors for many years, but this possession did not alter the nature of the property. On Issue 2: The Supreme Court ruled that the Bambang River and the portion where the fish weir is constructed, along with its waters, are properties of public dominion. Citing Articles 399 and 407 of the Civil Code and relevant provisions of the Water Law, the Court stated that rivers, their natural beds, and waters are public dominion and cannot be occupied or appropriated for private and exclusive use by any individual. Such properties are considered outside the commerce of man. Therefore, even though Meneses had occupied the portion of the riverbed for many years as owner and used it for a fish weir, this occupation did not grant him ownership. The Court reiterated that properties of public dominion are not only not susceptible to appropriation but also to prescription, making them imprescriptible as per Article 1936 of the Civil Code. The claim of ownership by Meneses over this part of the river was thus dismissed.
Main Doctrine
Rivers, their natural beds, and waters are classified as property of public dominion. Consequently, they are outside the commerce of man and cannot be acquired by private individuals through purchase, appropriation, or prescription, irrespective of the length of possession. Any construction or obstruction within a riverbed, such as a fish weir, without proper government permit is unlawful and subject to removal.