Case Digest (G.R. No. 66575)
Facts:
- Petitioners: Adriano Maneclang and his family
- Respondents: Intermediate Appellate Court and members of the Municipal Council of Bugallon, Pangasinan
- Nature of Case: Complaint for quieting of title over a fishpond within four parcels of land in Barrio Salomague, Bugallon, Pangasinan
- Municipal Resolutions: Nos. 38 and 95 pertained to municipal waters and public bidding for the lease of municipal ferries and fisheries, including the disputed fishpond
- Trial Court Decision: Dismissed the complaint on August 15, 1975, ruling that the body of water was a creek and public in nature
- Intermediate Appellate Court Decision: Affirmed the trial court's decision on April 29, 1983
- Supreme Court Proceedings: Petitioners sought a review on certiorari, but the Supreme Court found the Compromise Agreement contrary to law and public policy
Issue:
- (Unlock)
Ruling:
- No, a creek, being a public body of water, cannot be subject to private ownership and appropriation.
- The Compromise Agreement recognizing the petitioners' ownership over the fishpond is null and void.
- The petitioners were not deprived o...(Unlock)
Ratio:
Creek as Public Domain: The Supreme Court held that a creek is a property belonging to the public domain and is not susceptible to private appropriation and acquisitive prescription.
Established Principles: Cited Mercado vs. Municipal President of Macabebe (59 Phil. 592, 1934) and affirmed in Diego v. Court of Appeals (102 Phil. 494) and Mangaldan v. Manaoag (38 Phil. 455).
Nature of Creek: The construction of irrigation dikes and conversion into a fishpond did not change the creek's public nature.
Compromise Agreement: Found null and void for being contrary to law and public policy.
Authority of Municipal Council: The Municipality of Bugallon had the authority to pass resolutions dealing with its municipal waters.
Due...continue reading
Case Digest (G.R. No. 66575)
Facts:
The case of "Maneclang v. Intermediate Appellate Court" involves petitioners Adriano Maneclang and his family, who filed a complaint for quieting of title over a fishpond located within four parcels of land they owned in Barrio Salomague, Bugallon, Pangasinan. The respondents in the case include the Intermediate Appellate Court and several members of the Municipal Council of Bugallon, Pangasinan, namely Alfredo Maza, Corleto Castro, Salome Rodriguez, Eduardo Cuison, Fernando Zarcilla, Mariano Gabriel, Nicomedes Cordero, Cleto Pedrozo, Felix Salary, and Jose Panlilio. The petitioners sought to annul Resolutions Nos. 38 and 95 passed by the Municipal Council, which pertained to the municipal waters and the public bidding for the lease of municipal ferries and fisheries, including the disputed fishpond.
The trial court dismissed the complaint on August 15, 1975, finding that the body of water traversing the petitioners' titled properties was a creek, a tributary of the Agno River, and thus public in nature and not subject to private appropriation. The court also upheld the validity of the municipal resolutions. The petitioners appealed to the Intermediate Appellate Court, which affirmed the trial court's decision on April 29, 1983. Subsequently, the petitioners sought a review on certiorari by the Supreme Court. During the proceedings, the petitioners and respondents attempted to settle the case amicably through a Compromise Agreement, which recognized the petitioners' ownership of the land and the water within their titled properties. However, the Supreme Court foun...