Case Summary (G.R. No. L-21673)
Determination of Factual Questions by the Secretary of Public Works and Communications
- The Secretary of Public Works and Communications exercises powers under Republic Act 2056, which necessitates determining factual questions, including the existence and navigability of a stream.
- Such functions are incidental to the authority granted by law to clear navigable streams of unauthorized obstructions or encroachments, as established in Lovina vs. Moreno.
Respect for Findings of Fact
- The findings of fact made by the Secretary of Public Works and Communications in the context of clearing navigable streams are entitled to respect from the courts.
- This respect is maintained in the absence of fraud, collusion, or grave abuse of discretion.
Test of Navigability
- A river is considered navigable if it can be used for commercial purposes in its natural state, regardless of the mode of commerce.
- The capability of floating vessels, boats, or logs in quantities that confer commercial value is sufficient for a river to be classified as navigable.
Floatability Under Republic Act 2056
- According to civil law, a navigable river is defined as "floatable," meaning it can accommodate floats.
- A river with a depth of one foot at low tide is deemed navigable at high tide for vessels of deeper draft, thereby applying floatability as the standard for navigability under Republic Act 2056.
Background of the Case
- Francisco Macatangay applied for temporary agricultural use of a 1,200-square meter land in Sta. Clara, Batangas, and was issued a permit.
- He constructed dikes and fillings on the eastern bank of the Clara River, leading to a complaint filed by Mariano Dilay for alleged illegal encroachment into the river.
Findings of the Secretary of Public Works and Communications
- After a hearing, the Secretary determined that the river was navigable and that Macatangay's constructions encroached upon it, violating Republic Act 2056.
- An order was issued for the removal of the constructions and restoration of the riverbed.
Court Proceedings and Rulings
- Macatangay filed a petition for prohibition and a preliminary injunction, which was granted temporarily.
- However, the Court of First Instance later denied the petition, affirming the navigability of the river and the binding nature of the Secretary's findings.
Appellant's Arguments
- Macatangay contended that the river was not navigable and that the Secretary's findings were not binding on the courts.
- He argued that the river only allowed passage for small boats and was not used as a highway of commerce.