G.R. No. L-31271. April 29, 1974.
Romeo Martinez and Leonor Suarez, spouses, petitioners-appellants, vs. Hon. Court of Appeals, Secretary and Undersecretary of Public Works & Communications, respondents-appellees.

FACTS

Petitioners are the registered owners of a fishpond in Lubao, Pampanga, covered by Transfer Certificate of Title No. 15856. The property’s chain of title traces back to a Spanish-era “titulo real” and a 1925 land registration decree issued despite opposition from the Attorney-General and the Director of Forestry. In 1954, the Committee on Rivers and Streams, after investigation, decided the creek within the property was private and ordered petitioners be restored to its possession. Acting on this, petitioners constructed dikes. However, in 1958, the Secretary of Public Works and Communications, invoking Republic Act No. 2056 , ordered the dikes’ removal, alleging the area was a public navigable waterway. Petitioners then filed an action to annul this administrative order.
The Court of First Instance of Pampanga ruled in favor of the petitioners, upholding their registered title. On appeal, the Court of Appeals reversed this decision. It upheld the administrative order, dissolved the injunction, and ordered the cancellation of the registration of the disputed portion (Lot No. 2) and its reconveyance to the public domain. The appellate court noted that the deed of sale by which petitioners acquired the property explicitly stated the lot was “currently open, without dikes” and that the buyers assumed all risk and expense for any government action preventing its conversion back into a fishpond.

ISSUE

Whether the Court of Appeals erred in upholding the administrative order for the removal of the dikes and ordering the cancellation of the petitioners’ registered title over the disputed land.

RULING

The Supreme Court affirmed the Court of Appeals’ decision. The legal logic rests on the inalienability of public navigable waters and the petitioners’ failure to qualify as purchasers in good faith. The Court held that rivers and navigable waterways are part of the public domain and cannot be appropriated privately, nor can title be acquired by prescription. A Torrens title cannot vest ownership where the property is legally incapable of private appropriation. The 1925 registration decree, issued despite state opposition, did not legitimize the private claim over what was essentially public property.
Crucially, the petitioners were not innocent purchasers for value. Their own deed of sale contained explicit admissions that the lot was open and without dikes due to a prior administrative order, and they voluntarily assumed all risks and costs associated with seeking government permission to re-convert it. By purchasing with full knowledge of these defects and legal obstacles, they cannot invoke good faith or rely solely on the face of the title. The principle that a purchaser need not look beyond the certificate of title does not apply when the subject property is, by its very nature as a waterway, outside the commerce of man and incapable of private ownership. Therefore, the administrative order under Republic Act No. 2056 was valid, and the reconveyance of the property to the public domain was proper.