G.R. No. L-24281 May 16, 1967
ROSITA C. TALEON and MIGUEL SOLIS, petitioners-appellants, vs. THE SECRETARY OF PUBLIC WORKS AND COMMUNICATIONS, THE DISTRICT ENGINEER, Province of Davao, and LUCIA O. TOLENTINO, respondents-appellees.

FACTS

Petitioner Rosita Taleon is the registered owner of a parcel of land in Lupon, Davao, which she acquired from her co-petitioner Miguel Solis, who had constructed man-made canals and fishpond dikes therein. Respondent Lucia Tolentino filed a complaint with the Secretary of Public Works, alleging that several fishpond owners, including Taleon and Solis, had built dams across and closed the Cabatan River, a public navigable stream, depriving residents of passageway, fishing ground, and water supply. After an administrative hearing, the Secretary of Public Works, through the undersecretary, rendered a decision on July 11, 1961, finding that the appellants were obstructing the Cabatan River with their dams and ordering their demolition. Appellants’ motion for reconsideration was denied. They appealed to the Office of the President, which affirmed the decision on November 10, 1961. Appellants filed a motion for reconsideration based on an alleged new decision by Secretary Moreno dated November 24, 1961, reversing the earlier ruling. The Office of the President denied the motion, stating that the alleged decision was not part of the records and, even if genuine, had no legal effect as the Secretary had lost jurisdiction due to the appeal. Upon being notified of the impending demolition, appellants filed suits in the Courts of First Instance of Davao and Manila to stop it. The Court of First Instance of Manila, after pre-trial and upon respondents’ motion to dismiss, dismissed the petition, finding that appellants were given a fair administrative hearing and the decision was supported by evidence. Appellants appealed.

ISSUE

1. Whether the trial court erred in dismissing the case without a full trial to allow appellants to prove that the body of water was a mere depression and that Secretary Moreno’s later decision was genuine.
2. Whether the Secretary of Public Works had jurisdiction over the case concerning dams and a body of water located inside registered private property.

RULING

The Supreme Court affirmed the trial court’s dismissal. On the first issue, the Court ruled that a full trial was unnecessary as the issues raised were purely legal and could be resolved based on the pleadings, memoranda, and administrative records. The review of an administrative finding is limited to the evidence presented before the administrative body, barring new evidence. The trial court properly examined the administrative records and found substantial evidence supporting the finding that the depression was part of the navigable Cabatan River. Regarding the alleged second decision of Secretary Moreno, its non-existence was officially certified by the custodian of records. Even if genuine, it lacked legal force because the Secretary had lost jurisdiction after appellants appealed to the Office of the President, which had affirmed the original decision.
On the second issue, the Court, citing Lovina v. Moreno, upheld the jurisdiction of the Secretary of Public Works under Republic Act 2056 to declare any alleged depression or body of water, even inside titled properties, as a public navigable stream. This fact-finding power is incidental to the duty to clear navigable streams of obstructions and does not constitute an unlawful delegation of judicial power. A public stream is not subject to private appropriation, and a land title’s silence on the existence of a stream does not confer a private right over it. The trial court was authorized by the Rules of Court to render judgment based on the pleadings and administrative records after pre-trial, as all necessary facts were already before it.