Case Summary (G.R. No. L-31271)
Administrative and Judicial Proceedings
Pursuant to RA 2056, the Secretary ordered removal of petitioners’ dikes in 1958. Petitioners sought relief in the Court of First Instance, which nullified the administrative order and made the preliminary injunction permanent. The Department appealed to the Court of Appeals, which reversed and ordered cancellation of Lot No. 2’s registration and reconveyance to the public domain. Petitioners then sought certiorari review before the Supreme Court.
Torrens Title Indefeasibility and Public Domain Exception
Petitioners argued that Lot No. 2’s Torrens certificate was indefeasible and res judicata, having been validly registered in 1925 and unchallenged within one‐year review period under Act 496 § 38. The Court held that public navigable rivers are non-registrable under Act 496 § 39 and Civil Code Art. 339, thus outside Torrens protection. A certificate covering unregistrable public property is voidable anytime by the State, which holds the reversionary right to public domain and is not barred by prescription.
Authority Under Republic Act No. 2056
The Secretary of Public Works’ power under RA 2056 to remove obstructions in public navigable waters is valid and nondelegable. Petitioners’ prior favorable judicial and administrative findings do not preclude the Secretary’s authority to enforce statutory prohibitions on dikes impeding navigation.
Assignment of Errors I & II: Collateral Attack and Res Judicata
The Supreme Court found no collateral‐attack prohibition when Torrens titles include public domain features. Citing jurisprudence, it reaffirmed that land registration courts lack jurisdiction over unregistrable public streams, so subsequent administrative or judicial orders may annul such title inclusions regardless of prior recordings or final decrees.
Assignment of Error III: Good-Faith Purchaser Claim
Petitioners contended they bought Lot No. 2 in good faith and for value. The conveyance, however, exp
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Facts
- Petitioners-appellants Romeo Martinez and Leonor Suarez hold Transfer Certificate of Title (TCT) No. 15856 covering two parcels of fishpond land in Lubao, Pampanga; Lot No. 2 is the subject of controversy.
- Original ownership traced to Paulino Montemayor (título real, 1883); passed to Maria and Donata Montemayor, then sold to Potenciano Garcia.
- 1914: Garcia sued municipal president Pedro Beltran (C.I. Case No. 1407) to protect his possession and dikes on Lot No. 2; preliminary injunction issued, made permanent in 1916, and affirmed by the Supreme Court in 1918.
- 1925: Garcia successfully registered both parcels in his name despite opposition by the Attorney General and Director of Forestry; Original Certificate of Title No. 14318 issued.
- Subsequent ownership transfers led to issuance of TCT No. 15856 in favor of the spouses Martinez and Suarez.
- 1953: Petitioners sought to repair Lot No. 2’s dikes but were obstructed by Lubao municipal officials.
- Petitioners and municipal authorities referred the dispute to the Committee on Rivers and Streams; Sub-Committee ocular inspection (March 11, 1954) and committee decision (July 7, 1954) declared the creek a private fishpond.
- September 1, 1954: Petitioners secured preliminary injunction in CFI Case No. 751 against Acting Mayor Zagad; Supreme Court dismissed mayor’s petition for review, upholding injunction.
- June 13, 1958: Republic Act No. 2056 enacted empowering the Secretary of Public Works & Communications to remove unlawful dikes in public navigable waters.
- November 25, 1958: Secretary Moreno ordered petitioners to remove their dikes on Lot No. 2 within 30 days or face demolition.
- January 2, 1959: Petitioners filed the present action in CFI of Pampanga to annul the Secretary’s order and to make the preliminary injunction perpetual.
- August 10, 1959: CFI rendered judgment in favor of petitioners, nullifying the administrative order and making the injunction permanent.
Procedural History
- Respondents (Secretary and Undersecretary of Public Works & Communications) appealed the CFI decision to the Court of Appeals.
- November 17, 1969: Court of Appeals (CA-G.R. 27655-R) reversed the CFI, holding:
• Validity of the administrative decision ordering removal o