G.R. No. L-46268 September 24, 1986
NATIONAL POWER CORPORATION, petitioner, vs. HONORABLE COURT OF APPEALS and CONRADO B. PAYUMO, respondents.

FACTS

Conrado B. Payumo filed an application for land registration over a 15-hectare parcel in Norzagaray, Bulacan, alleging ownership by purchase in 1937 and continuous possession for thirty years. The National Power Corporation (NPC) opposed, asserting the land was part of the Angat River Watershed Reservation established by Presidential Proclamation No. 599 on June 23, 1959, and was thus inalienable public land. The Court of First Instance of Bulacan dismissed Payumo’s application, declaring the land public and part of the NPC-administered reservation, finding Payumo failed to prove credible possession and noting a longstanding dispute over the property with the Castillo claimants. The Court of Appeals reversed, granting Payumo’s application. It held his possession met the 30-year requirement under Republic Act No. 1942 and that his rights, being prior and vested, were protected by the proclamation’s “subject to private rights” clause. NPC elevated the case to the Supreme Court.

ISSUE

Whether Payumo had acquired a vested private right over the land prior to the issuance of Proclamation No. 599, thereby exempting it from the reservation.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision, declaring the land public and part of the Angat River Watershed Reservation. The legal logic centered on the requirement for a conclusive right under the Public Land Act. For judicial confirmation of an imperfect title, an applicant must prove open, continuous, exclusive, and notorious possession and occupation under a claim of ownership for at least thirty years immediately preceding the filing of the application. The Court found Payumo failed to meet this burden. His claim of possession since 1937 was vitiated by evidence of a persistent dispute with the Castillos, which negated the exclusivity and peacefulness required by law. Crucially, a prior Court of Appeals decision involving the same parties had already declared the land public domain. Since Payumo’s application was filed in October 1959, he needed to prove possession since at least October 1929. He did not. Therefore, at the time Proclamation No. 599 was issued in June 1959, Payumo’s inchoate interest had not yet ripened into a vested right that could be saved by the proclamation’s “subject to private rights” clause. A right becomes absolute only upon full compliance with legal requirements. Consequently, the land remained part of the inalienable public domain reserved for the NPC.