Case Digest (G.R. No. L-21673)
Facts:
- Francisco Macatangay is the petitioner and appellant against the Secretary of Public Works and Communications and Mariano Dilay, the respondents and appellees.
- On April 14, 1961, Macatangay applied for a temporary agricultural use permit for a 1,200-square-meter parcel of land in Sta. Clara, Batangas.
- He received the permit on April 17, 1961, valid for one year, expiring on April 16, 1962, after paying a fee of P5.00.
- Macatangay made improvements to the land, constructing dikes and fillings along the eastern bank of the Sta. Clara River (Pantalan River).
- On September 5, 1961, Mariano Dilay filed a complaint against Macatangay, claiming his constructions encroached upon the riverbed, violating Republic Act 2056.
- A hearing was conducted by the Secretary of Public Works and Communications, who determined the river was navigable and that Macatangay's constructions were illegal.
- The Secretary ordered the removal of the dikes and restoration of the riverbed.
- After a motion for reconsideration was denied, Macatangay filed a petition for prohibition with a preliminary injunction on February 6, 1962.
- The Court of First Instance of Batangas granted a preliminary injunction on February 15, 1962, but later denied the petition and dissolved the injunction on March 21, 1963.
- Macatangay appealed directly to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed that the Sta. Clara River is navigable.
- The Court ruled that the findings of the Secretary of Public Works and Communications are binding upon the courts in the absence of fraud, collusion, or grave abuse of discretion. ...(Unlock)
Ratio:
- The Supreme Court emphasized that the determination of navigability is a factual question within the Secretary's purview.
- The Court referenced the case of Lovina vs. Moreno, establishing that the Secretary's findings under Republic A...continue reading
Case Digest (G.R. No. L-21673)
Facts:
The case involves Francisco Macatangay as the petitioner and appellant against the Secretary of Public Works and Communications and Mariano Dilay as the respondents and appellees. On April 14, 1961, Macatangay applied to the Bureau of Lands for a temporary agricultural use permit for a 1,200-square-meter parcel of land located in Sta. Clara, Batangas. He was granted a permit on April 17, 1961, which was valid for one year, expiring on April 16, 1962, after paying a fee of P5.00. Following this, Macatangay made improvements to the land by constructing dikes and fillings along the eastern bank of the Sta. Clara River, also known as the Pantalan River. On September 5, 1961, a complaint was filed against him by Mariano Dilay, the barrio lieutenant of Sta. Clara, on behalf of the local residents, alleging that Macatangay's constructions encroached upon the riverbed, thereby violating Republic Act 2056. The Secretary of Public Works and Communications conducted a hearing and, on November 29, 1961, determined that the river was navigable and that Macatangay's constructions were illegal encroachments. Consequently, he ordered the removal of the dikes and restoration of the riverbed. After his motion for reconsideration was denied, Macatangay filed a petition for prohibition with a preliminary injunction in the Court of First Instance of Batangas on February 6, 1962. The court granted a preliminary injunction...