Mateo vs. Moreno

The Court held that Republic Act No. 2056 does not constitute an undue delegation of judicial power, and that the Secretary of Public Works and Communications possesses valid administrative authority to investigate and determine the navigability of streams and order the removal of obstructions therein. The governing principle is that findings of fact made by administrative agencies pursuant to such authority are deemed conclusive upon judicial review provided they are supported by substantial evidence, defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

Residents of Guiguinto, Bulacan, sent a letter-complaint to the Highway District Engineer in 1959 requesting that Sapang Cabay, a stream allegedly blocked by dikes and dams and converted into fishponds, be reopened and restored to its original condition. The complaint was referred to the Secretary of Public Works and Communications, who conducted an investigation pursuant to Republic Act No. 2056. Acting on the investigator's report, the Secretary rendered a decision finding that the Sapang Cabay was a public navigable stream and ordering the property owner to remove the obstructions.

• In 1959, residents of Guiguinto, Bulacan, complained that Sapang Cabay had been blocked by dikes and dams and converted into fishponds, depriving the public of its use.
• The Secretary of Public Works and Communications investigated pursuant to Republic Act No. 2056.
• On August 10, 1959, the Secretary issued a decision finding Sapang Cabay to be a public navigable stream and ordering petitioner Cenon Mateo, who had acquired the property containing the creek, to remove the dikes and dams within thirty days.
• Mateo's motion for reconsideration was denied.
• Evidence presented during the investigation indicated that the creek was 70 to 75 meters wide at its widest portion; that residents historically used it for fishing, gathering nipa palms and fuel, and navigation by bancas; that a man-made canal diverted water from the creek's original path; and that the closure caused flooding in surrounding ricelands.
• Witnesses, including elderly residents aged 64 to 79, testified regarding the public use of the creek prior to its closure and the subsequent flooding of surrounding areas.
• Documentary evidence showed that as early as 1941, the municipal council had requested the removal of obstructions, and that in 1954, the Secretary had ordered Mateo's predecessor-in-interest, Encarnacion Jacobo, to remove the dikes.
• In 1953, Jacobo secured a free patent and a corresponding certificate of title covering the property, notwithstanding the pending administrative proceedings.

• Petitioner maintained that the Secretary lacked jurisdiction to conduct the investigation and order the removal of the dikes, arguing that the determination of whether a body of water is private property or a public navigable stream is essentially a judicial question.
• Petitioner argued that Republic Act No. 2056 is unconstitutional because it unduly delegates judicial power to the Secretary and unlawfully deprives property owners of due process.
• Petitioner contended that Republic Act No. 2056 is inapplicable to the instant case.
• Petitioner asserted that the Sapang Cabay is not a public navigable waterway but private property covered by a Torrens Certificate of title, which should be given legal effect.
• Petitioner argued that the Secretary's conclusion that the creek is navigable constitutes a grave abuse of discretion in light of the established facts.

• Respondent contended that Republic Act No. 2056 is constitutional and validly confers jurisdiction upon the Secretary to determine questions of navigability and obstruction.
• Respondent argued that the findings of fact by the Secretary are supported by substantial evidence, including testimonial and documentary proof of the creek's navigability and public use.
• Respondent maintained that a certificate of title does not preclude a subsequent determination that the land is actually a navigable waterway belonging to the public domain, and that ownership of such waterways is not subject to acquisitive prescription.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether Republic Act No. 2056 is unconstitutional for delegating judicial power to the Secretary and depriving property without due process.
  • Whether the Secretary of Public Works and Communications has jurisdiction to investigate and determine whether a body of water is a navigable stream of the public domain.
  • Whether the Secretary's finding that Sapang Cabay is a public navigable stream is supported by substantial evidence.
  • Whether a Torrens Certificate of Title covering the property precludes a subsequent administrative determination that it is a public navigable waterway.

• Procedural:
  • N/A
• Substantive:
  • The Court held that Republic Act No. 2056 is constitutional and does not constitute an undue delegation of judicial power, citing Lovina vs. Moreno.
  • The Court ruled that the Secretary has jurisdiction to investigate and determine whether a river or creek is navigable and belongs to the public domain, and whether dikes and dams constitute prohibited constructions.
  • The Court found that the Secretary's determination that Sapang Cabay is a public navigable stream is supported by substantial evidence, defined as "more than a scintilla" and "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion."
  • The Court held that the absence of any mention of a navigable stream in a certificate of title does not preclude a subsequent investigation and determination of its existence, nor does it make the waterway private property of the title holder.
  • The Court ruled that ownership of a navigable stream or its bed is not subject to acquisitive prescription, and that the certificate of title issued to the predecessor-in-interest did not change the public character of Sapang Cabay, being covered by the exceptions in Section 39 of Act No. 496.
  • The Court affirmed the dismissal of the petition for injunction.

• Substantial Evidence Rule — Defined as evidence that is more than a scintilla and consists of such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Under this rule, courts do not reassess the evidence or substitute their own findings for those of the administrative agency; judicial review is limited to determining whether the record contains substantial evidence to support the agency's findings.
• Public Domain Status of Navigable Waters — Navigable streams and their beds belong to the public domain; ownership thereof is not subject to acquisitive prescription and cannot be acquired by private title.
• Effect of Torrens Title on Public Waters — A certificate of title issued under the Torrens system does not preclude a subsequent administrative or judicial determination that land covered thereby is actually a navigable waterway belonging to the public domain, as navigable waters are excepted from the operation of registration decrees under Section 39 of Act No. 496.

• "Substantial evidence, it has been held, 'is more than a scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'" — Defining the standard of proof required to uphold administrative findings of fact.
• "Under this rule the courts are not supposed to reassess the evidence, determine its preponderance on either side, and substitute its own findings for those of the administrative agency. All that the court does is to inquire from the record if the findings are based on substantial evidence. If so, the findings are deemed conclusive." — Explaining the limited scope of judicial review over administrative factual determinations.

• Lovina vs. Moreno, G.R. No. L-17821, November 29, 1963 — Controlling precedent upholding the constitutionality of Republic Act No. 2056, affirming the Secretary's jurisdiction to determine navigability, and holding that a certificate of title does not preclude subsequent determination that land is a public navigable waterway.
• Consolidated Edison Co. vs. N.L.R.B., 305 U.S. 197 (1938) — Cited for the definition of substantial evidence.
• Ang Tibay vs. CIR, 69 Phil. 635 — Cited alongside Consolidated Edison regarding the substantial evidence standard.
• Mercado vs. Macabebe, 59 Phil. 592 — Cited in relation to Section 39 of Act No. 496 regarding exceptions to the operation of a decree of registration.

• Republic Act No. 2056 — Statute conferring upon the Secretary of Public Works and Communications the authority to investigate complaints regarding obstructions in navigable streams and order their removal.
• Section 31 of Republic Act No. 296 — Provision allowing certification of cases from the Court of Appeals to the Supreme Court when constitutional questions are involved.
• Section 39 of Act No. 496 (The Land Registration Act) — Provision enumerating exceptions to the operation of a decree of registration, including navigable waters.