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, o...

Facts:

1. Application for Land Use:

• On April 14, 1961, Francisco Macatangay applied to the Bureau of Lands for temporary agricultural use of a 1,200-square-meter land in Sta. Clara, Batangas.
• On April 17, 1961, he was issued a permit valid for one year, expiring on April 16, 1962, upon payment of P5.00.

2. Introduction of Improvements:

• Macatangay introduced improvements, including dikes and fillings, on the eastern bank of the Sta. Clara River (also known as the Pantalan River).

3. Complaint Filed:

• On September 5, 1961, Mariano Dilay, the barrio lieutenant of Sta. Clara, filed a complaint with the Secretary of Public Works and Communications on behalf of the barrio people.
• The complaint alleged that Macatangay's dikes and fillings encroached into the Sta. Clara River, incorporating part of the riverbed into his fishpond, to the detriment of the public.

4. Secretary's Decision:

• After notice and hearing, the Secretary of Public Works and Communications found on November 29, 1961, that the Sta. Clara River was navigable and used by the public for passage and fishing.
• The Secretary ruled that Macatangay's constructions violated Republic Act 2056 and ordered the removal of the encroachments and restoration of the river to its previous condition.

5. Legal Proceedings:

• Macatangay filed a motion for reconsideration, which was denied.
• On February 6, 1962, he filed a petition for prohibition with preliminary injunction in the Court of First Instance of Batangas.
• The court issued a preliminary injunction on February 15, 1962, to restrain the enforcement of the Secretary's decision.
• On March 21, 1963, the Court of First Instance denied the petition for prohibition and dissolved the preliminary injunction, upholding the Secretary's findings.

6. Appeal to the Supreme Court:

• Macatangay appealed directly to the Supreme Court, challenging the navigability of the river and the binding nature of the Secretary's findings.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Navigability Under Republic Act 2056:

   • A river is navigable if it is capable of being used for commerce or transportation, even if only by small boats or bancas.
   • The Sta. Clara River meets this criterion, as it is used by residents for transporting goods and supplies.

2. Respect for Administrative Findings:

   • Courts should respect the factual findings of administrative agencies, such as the Secretary of Public Works and Communications, when such findings are supported by evidence and made in the exercise of their statutory powers.

3. Public Interest Over Private Claims:

   • The protection of public navigable rivers and waterways takes precedence over private interests, especially when private constructions impede public use and access.

4. Applicability of American Jurisprudence:

   • The Court rejected Macatangay's reliance on American jurisprudence, emphasizing that under Philippine law, a river is navigable if it is "floatable" and capable of being used for transportation, regardless of the size of the vessels.

Judgment Affirmed.