Case Summary (G.R. No. L-66575)
Subject Matter and Initial Proceedings
The petitioners sought quieting of title over a fishpond located within four parcels of their land in Barrio Salomague, Bugallon, Pangasinan. They also sought annulment of Municipal Council Resolutions Nos. 38 and 95 of Bugallon, which authorized ocular inspection of the Cayangan Creek and public bidding for the lease of municipal ferries and fisheries, including the fishpond in dispute. The trial court dismissed the complaint on August 15, 1975, ruling that the water body traversing petitioners’ properties was a creek, part of a tributary of the Agno River, thus belonging to the public domain and not subject to private ownership.
Appellate Court Decision and Petitioners’ Appeal
The petitioners appealed to the Intermediate Appellate Court, which affirmed the trial court’s decision on April 29, 1983. The appellate court upheld that the Municipal Council’s issuance of the resolutions was proper legislative action regarding municipal waters and that the creek belonged to the public. This led the petitioners to file a petition for review on certiorari before the Supreme Court.
Compromise Agreement and Parties’ Manifestation
Before the respondents could file comments on the petition, the petitioners manifested the desire to settle the case amicably due to the lack of interest from respondent Alfredo Maza, the successful bidder for the fishpond lease. They submitted a Compromise Agreement seeking recognition of ownership over the fishpond, asserting that the National Irrigation Administration (NIA) had constructed a dike around the land preventing water flow, thereby changing the nature of the water body.
Legal Analysis on Nature of the Creek and Public Domain
The Court emphasized that a creek, defined as a recess or arm extending from a river with tidal fluctuations, is part of the public domain and is exempt from private appropriation and acquisitive prescription. The Court cited the landmark ruling in Mercado vs. Municipal President of Macabebe, where it was held that such waterways are public property and cannot be registered or owned privately under the Torrens system. The decisions in Diego v. Court of Appeals and Mangaldan v. Manaoag further reinforced that public waters cannot be appropriated privately.
Invalidity of the Compromise Agreement
The Court ruled that the Compromise Agreement, which effectively adjudicated ownership of the fishpond to the petitioners, is null and void. This is because neither the construction of the irrigation dike by NIA nor the conversion of the creek into a fishpond altered its nature as public domain property. The Court treated the determination that the water body was a creek belonging to the public domain as a factual finding, binding upon the Court.
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Facts and Procedural Background
- Petitioners Adriano Maneclang and others filed a complaint before the Court of First Instance of Pangasinan, Branch XI, seeking quieting of title over a certain fishpond located within four parcels of their land in Barrio Salomague, Bugallon, Pangasinan.
- They also sought the annulment of Municipal Council of Bugallon Resolutions Nos. 38 and 95.
- Resolution No. 38 ordered an ocular inspection of the Cayangan Creek situated between Barrios Salomague Sur and Salomague Norte.
- Resolution No. 95 authorized public bidding for the lease of all municipal ferries and fisheries, including the fishpond under dispute.
- The trial court dismissed petitioners’ complaint on August 15, 1975, ruling that the body of water traversing their titled properties was a creek constituting a tributary of the Agno River, thus public and not subject to private appropriation.
- The court upheld the municipal council’s authority to pass the resolutions in the exercise of its legislative powers.
- Petitioners appealed the decision to the Intermediate Appellate Court, which affirmed the dismissal on April 29, 1983.
- Subsequently, petitioners filed a petition for review on certiorari before the Supreme Court.
Issue Presented
- Whether the petitioners could acquire ownership over the fishpond located within their titled land, which was originally a creek belonging to the public domain.
- Whether the Compromise Agreement submitted by the parties, recognizing petitioners’ ownership over the fishpond, is valid and binding.
- Whether the resolutions passed by the Municipal Council regarding the inspection and leasing of the municipal waters were validly enacted and whether due process was observed.
Parties’ Contentions and Supreme Court’s Actions
- Respondents were required to c