G.R. No. 48293 - People vs. Gonzalez

Numerous residents of Macabebe, Pampanga, petitioned the Secretary of Public Works and Communications (PW&C) under Republic Act No. 2056, alleging that spouses Primitivo Lovina and Nelly Montilla had blocked the Sapang Bulati, a navigable river, by constructing dams and dikes on their registered fishpond (TCT No. 15905).
After due notice and a hearing, the Secretary, by decision of 11 August 1959, found the works to be public nuisances and ordered their removal within thirty days, failing which removal would be effected at the Lovinas’ expense.
The Lovinas filed Civil Case No. 41639 in the Court of First Instance (CFI) of Manila seeking a permanent injunction restraining enforcement of the Secretary’s order.

The CFI granted the injunction, effectively staying compliance with the Secretary’s decision.
Secretary Florencio Moreno and investigator Benjamin Yonson (appellants) appealed to the Supreme Court, challenging the CFI’s rulings.

The CFI lacked jurisdiction or erred in holding RA 2056 unconstitutional.
The CFI improperly received evidence de novo and substituted its judgment for that of the Secretary.
The CFI mischaracterized the Sapang Bulati as a private stream and erred in finding non‐navigability.
The appellees failed to exhaust administrative remedies.

Section 1: Any works encroaching on public navigable waters or communal fishing grounds are public nuisances and must be removed, except as authorized by the Secretary when public interest or safety so requires.
Section 2: After notice and hearing, the Secretary may order removal within thirty days, effect removal at the party’s expense, and must conclude proceedings within ninety days. Exemptions and penalties for delay are provided; completed good‐faith fishponds not obstructing navigation are protected.

Secretary’s investigator found that Sapang Bulati originally flowed across the registered lot, 2 m deep at high tide, navigated by bancas, and was closed by predecessor Jose de Jesus via 800 m of dams.
The CFI, relying on the 1916 Torrens plan (Exh. C), deemed the creek a mere estero not delimited within the lot and not navigable at the time of registration.

Does Republic Act No. 2056 constitute an unconstitutional delegation of judicial power to the Secretary of Public Works and Communications?
Did the CFI err in receiving evidence de novo and substituting its findings for those of the Secretary?
Does a Torrens title confer ownership of navigable streams not expressly delimited in the registration plan?
Are the Secretary’s factual findings under RA 2056 binding in the absence of fraud, collusion, grave abuse of discretion, or error of law?
Was it necessary for the appellees to exhaust administrative remedies before seeking judicial relief?