G.R. No. L-24281 - Taleon vs. Secretary of Public Works and Communications

Petitioner-appellant Rosita C. Taleon is the registered owner of a parcel of land in Lupon, Davao.
The land was acquired from her co-petitioner-appellant Miguel Solis, who constructed man-made canals and fishpond dikes on it.

On April 17, 1961, respondent-appellee Lucia O. Tolentino sent a letter-complaint to the Secretary of Public Works.
Tolentino alleged that several fishpond operators/owners in Lupon had built dams across and effectively closed the Cabatan River, a public navigable stream.
She claimed that the closure affected passageway, fishing grounds, and water supply for residents.
On June 9, 1961, her complaint was amended to specifically include appellants Taleon, Solis, and an additional neighbor, Humberto de los Santos, as responsible parties.

On June 13, 1961, Taleon filed an answer denying the existence of the alleged river and asserted that the dams were constructed within her registered property.
She further argued that her water source was a man-made canal connected to the sea.
An administrative hearing was subsequently held.
On July 11, 1961, the Secretary of Public Works, through the department undersecretary, found that the appellants were indeed obstructing the Cabatan River with their dams and ordered their demolition.

The appellants filed a motion to reconsider the Secretary’s ruling, contesting both the facts and alleging lack of jurisdiction by the Secretary.
The motion for reconsideration was denied.
The appellants then elevated the case to the Office of the President on October 11, 1961.
On November 10, 1961, the Office of the President affirmed the July 11 ruling.
Appellants filed another motion to reconsider based on an alleged decision by Public Works Secretary Moreno on November 24, 1961, claiming it reversed the former ruling.
On January 10, 1962, the Office of the President denied the motion on two grounds:

The alleged Moreno decision was not part of the official records.
The Secretary had already lost jurisdiction once the appeal to the President was filed.

On February 9, 1962, Taleon was informed by the District Engineer of Davao that her dams would be demolished on February 16, 1962, following the now final and executory administrative decision.
To forestall the demolition, the appellants filed a suit in the Court of First Instance (CFI) of Davao and obtained a writ of preliminary injunction.
On September 1, 1962, a similar petition for certiorari and prohibition with a preliminary injunction was filed in the CFI of Manila.
After respective answers were filed and the Davao case dismissed, the Manila court issued the writ of preliminary injunction (in the nature of a temporary restraining order with bond).

A pre-trial conference was held wherein the respondents were allowed to file a motion to dismiss the petition.
The judicial officer ordered the administrative records to be submitted.
On January 11, 1965, based on the memoranda and records, the CFI of Manila ruled:

The petition was summarily dismissed with costs against the petitioners-appellants, and the temporary restraining order was dissolved.

Whether the Secretary of Public Works had the jurisdiction to declare a depression or watercourse, even within a privately titled property, as a public navigable stream.
Whether the construction of dams within the appellants’ property could legally restrict public rights over an alleged watercourse.

Whether a full trial was necessary given that the issues presented were purely legal and could be resolved on the basis of the pleadings, memoranda, and administrative records.
Whether the rule barring a trial de novo in administrative cases limited the appellants’ capacity to present new evidence (such as affidavits and aliunde testimonies) to contest the administrative findings.

Whether there existed a genuine second decision by Secretary Moreno reversing the July 11, 1961 ruling.
Whether, even if such a decision existed, it would have any binding legal effect given the prior appeal to the Office of the President and the subsequent affirmation of the original decision.