G.R. No. L-46268 - National Power Corp. vs. Court of Appeals

The dispute involves a parcel of land identified as Lot 1 of Plan Psu-167442, covering 15.3145 hectares in sitio Pamusuan, Barrio San Mateo, Norzagaray, Bulacan.
Conrado B. Payumo filed an application for registration on October 12, 1959, alleging ownership through purchase from his father-in-law, Mariano Palad, in February 1937, and claiming continuous, exclusive, and uninterrupted possession for a period of thirty years.
The land’s boundaries and ownership were further complicated by conflicting claims arising from historical Spanish titles and subsequent informal possession.

Opposition to Payumo’s application was filed by both private parties (the Castillos: Juan, Fausta, Ramon, Fabian, and Maria) and by the National Power Corporation (NPC).
The Castillos contended that the parcel formed part of a larger 4,000-hectare tract inherited from Don Mariano San Pedro y Esteban under a Spanish title (Titulo de Composicion con el Estado, dated April 21, 1894).
NPC insisted that a substantial portion of the land was public, being part of the Angat River Project, and had been reserved under Presidential Proclamation No. 599 (issued on June 23, 1959), which expressly reserved the land “subject to private rights.”

The Trial Court of Bulacan (April 14, 1966) ruled against both Payumo and the Castillos, declaring that neither had established any registerable right over the land.

The Court noted the failure of documentary evidence and credible testimony regarding the alleged purchase from Mariano Palad.
It observed that the possession claimed by Payumo was under a running dispute with the Castillos, thus preventing fulfillment of the “open, continuous, exclusive and notorious” possession requirement of the Public Land Act.
In reviewing the Castillos’ claim, the Court found the photostatic copy of the Spanish title suspect due to alterations increasing the size and altering the location of the original two small parcels.

The Court of Appeals, in its Decision dated May 4, 1977, reversed the Trial Court’s ruling, sustained Payumo’s adverse possession claim and granted his application for registration.

The Court of Appeals affirmed that adverse possession for a period of thirty years under R.A. 1942 was met, emphasizing that the application was filed in 1959—after the enactment of the law.
It held that any portion of the land falling within the Angat River Project did not negate Payumo’s claim due to a saving clause in Proclamation No. 599, which allowed for “private rights.”

NPC then sought judicial review of the Court of Appeals’ decision, challenging the prior findings and arguing that the land was indeed public and subject to the reservation under Proclamation No. 599.

Although he claimed possession since 1937, testimony indicated he had occupied the land for only about 20 years, and only declared it for tax purposes in 1959.
The alleged notarized deed of sale from Mariano Palad was never produced; additionally, there were issues with the chain of possession as testified in related appellate proceedings (e.g., CA-G.R. No. 22876-R).

The NPC argued that since the reservation under Proclamation No. 599 had been issued prior to Payumo instituting his claim, any unvested private rights were negated by the public declaration of the land for the Angat River Project.

Presidential Proclamation No. 599 (June 23, 1959) had already reserved a significant portion of the land for NPC’s Angat River Project before Payumo’s registration application was fully substantiated for the required period.
The dispute centers on whether Payumo’s claim of adverse possession, relying on a 30-year period of possession, was valid in light of ongoing disputes and the timing of the proclamation.

Whether the disputed parcel of land, partially included in the Angat River Project under Proclamation No. 599, can be registered as a private property through an adverse possession claim.
Whether Payumo had satisfactorily established the requisite 30-year period of “open, continuous, exclusive and notorious” possession necessary to acquire a private right over land classified as public under the reservation.
Whether the saving clause in Proclamation No. 599, which states the land is “subject to private rights,” effectively preserves existing private claims even after the public reservation.
Whether the evidence regarding the alleged purchase from Mariano Palad and the continuity of possession was sufficient and credible to support Payumo’s claim.