G.R. No. 45889 - Enriquez vs. People

Petitioner Crispino Enriquez owns a fishpond located in barrio Dalayap, Macabebe, Pampanga.
The fishpond comprises two separate parcels of land officially conveyed by a certificate of title.
The parcels are geographically separated by a portion of the Dalayap River, which is a navigable stream and subject to public ownership.
The fishpond is enclosed by dikes that, by including the intervening portion of the river, obstruct its free course.

On March 24, 1934, the Secretary of Public Works and Communications issued a letter to the petitioner stating that:

The Bureau of Public Works had determined that the petitioner and his wife, Maria Joaquin, had closed the Dalayap River and appropriated a portion within their fishpond.
Since the Dalayap River is of public ownership and navigable, its obstruction was deemed prejudicial to public interests.
The petitioner was ordered to remove the obstruction within 30 days from the receipt of the letter, failing which judicial action would be initiated under section 1926 of the Administrative Code.

After the petitioner, through counsel, denied the allegations regarding the closing of the river, the Secretary sent a subsequent letter on June 16, 1934, ordering the immediate removal of the obstruction.
Despite the petitioner’s request for a reinvestigation, no action was taken to comply with the removal order during the pendency of that request.

On August 16, 1934, the provincial fiscal of Pampanga filed an information before the Macabebe Justice of the Peace for the alleged violation of section 25-A of Act No. 3208.
The initial judgment imposed on the petitioner and his spouse included:

On appeal, the Court of First Instance of Pampanga increased the fine to one hundred pesos (₱100) for each accused, maintaining similar subsidiary incarceration provisions.
The Court of Appeals later affirmed the judgment with respect to the petitioner while acquitting his spouse.

The petitioner argued that the criminal action was premature, contending that his petition for reinvestigation should have suspended the running of the 30-day period fixed by law.
He further contended that his case was essentially civil in character, involving issues of ownership over the real property incorporated in the fishpond.
Additionally, the petitioner argued that section 25-A of Act No. 3208 amounted to an undue delegation of judicial power to the executive branch.

Whether the petitioner's request for reinvestigation had the effect of suspending the legally fixed 30-day period for the removal of the obstruction.
Whether the criminal action under section 25-A of Act No. 3208, pertaining to the removal of the obstacle obstructing a navigable waterway, was correctly characterized as criminal rather than civil in nature.
Whether section 25-A of Act No. 3208 constitutes an undue delegation of judicial power by authorizing the Secretary of Public Works and Communications to enforce removal orders affecting public waterways.