Case Summary (G.R. No. 45889)
Facts of the Case
Petitioner Crispino Enriquez owns a fishpond in Macabebe, Pampanga, encompassing two parcels of land separated by the Dalayap River, a navigable stream. The river has been obstructed by dikes constructed around the fishpond, causing concerns about the obstruction of the river's natural flow. On March 24, 1934, the Secretary of Public Works and Communications informed Enriquez that he had illegally closed the river, which is publicly owned, and requested that he remove the obstruction within thirty days or face legal action. Petitioner denied the allegations and requested a reinvestigation; however, he did not comply with the order to remove the obstruction.
Legal Proceedings
On August 16, 1934, the provincial fiscal of Pampanga filed charges against Enriquez and his wife, Maria Joaquin, for violating Section 25-A of Act No. 3208. Initially, they were sentenced to pay fines for their actions. Upon appeal to the Court of First Instance, the fines were increased, but Maria Joaquin was acquitted, while Enriquez's conviction was upheld. The case was subsequently elevated to the Court of Appeals, which maintained the lower court's decision regarding Enriquez.
Petitioner's Arguments
Enriquez contended that the criminal proceedings were premature due to the pendency of his request for reinvestigation when the charges were filed. He argued that the thirty-day period given by the Secretary was a legal timeframe that could not be disregarded and that the absence of an extension constituted an improper basis for filing charges against him. Furthermore, he asserted that the matter was purely civil, regarding property rights, and that the case should not be treated criminally.
Court's Analysis
The court found that the Secretary's order was clear and legally binding, and his request for removal adhered to a statutory deadline that required compliance. The court stated that the filing of a petition for reinvestigation does not inherently suspend the compliance period unless explicitly stated by the Secretary. It noted that if acquiesced, such delays might undermine public interest. The court clarified that the nature of the case addresses a violation of a legal order regarding public waters, making it criminal despite the petitioner's claim of ownership.
Delegation of Power
The petitioner also claimed that Section 25-A of Act No. 3208 constituted an undue delegation of judicial power. The court rejected this assertion, emphasizing that the Secretary's authority to order the removal of obstructions is e
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Case Background
- The petitioner, Crispino Enriquez, holds ownership of two parcels of land in Dalayap, Macabebe, Pampanga, designated for a fishpond, supported by a certificate of title.
- The parcels are bisected by the Dalayap river, recognized as a navigable stream and public property.
- The fishpond is encircled by dikes, which obstruct the river's flow and create a barrier.
Administrative Actions
- On March 24, 1934, the Secretary of Public Works and Communications notified Enriquez regarding the obstruction caused by the dikes to the Dalayap river, citing it as detrimental to public interests.
- The Secretary requested the removal of the obstruction within 30 days, threatening judicial action under section 1926 of the Administrative Code if compliance was not achieved.
- Enriquez, through legal counsel, denied the allegations and requested a reinvestigation.
Legal Proceedings
- Following Enriquez's failure to comply with the removal order, the provincial fiscal filed a case against him and his spouse, Maria Joaquin, in the justice of the peace court of Macabebe, for violating section 25-A of Act No. 3208.
- The justice of the peace court imposed a fine of fifty pesos (P50) on the defendants, with subsidiary imprisonment for failure to pay.
- Upon appeal, the Court of Fir