G.R. No. 208426 - Alvarado vs. Ayala Land, Inc.

Samuel M. Alvarado (petitioner) was the highest bidder in a tax delinquency sale of a 15,598-square-meter parcel in Quezon City, covered by Transfer Certificate of Title (TCT) No. N-253850, owned by Capitol Hills Golf and Country Club, Inc. (Capitol).
Respondents include Ayala Land, Inc., Ayala Hillside Estates Homeowners’ Association, Inc., and multiple individual members of Capitol who filed a complaint assailing the validity of the tax sale.
Respondents alleged that the sale was tainted with anomalies including improper notice, sale of the entire parcel instead of just the portion needed to cover unpaid taxes, and a grossly inadequate selling price.

The parcel was levied on November 16, 2007, due to unpaid real estate taxes amounting to ₱1,857,136.89 plus penalties, and sold at tax delinquency sale on December 13, 2007. Alvarado was the highest bidder at ₱2,600,000.00.
Respondents filed a complaint on December 7, 2010, questioning the validity of the tax sale citing violations of Section 260 of the Local Government Code and provisions of the Quezon City Revenue Code.
Alvarado filed an Answer with Compulsory Counterclaim and later a Motion to Dismiss, invoking procedural and jurisdictional grounds including failure to comply with the mandatory judicial deposit under Section 267 of the Local Government Code, failure to state a cause of action, and lack of subject matter jurisdiction since respondents allegedly lacked real legal interest on the property.
The Regional Trial Court (RTC) Judge Tita Marilyn Payoyo-Villordon denied the Motion to Dismiss and its reconsideration, ruling that the Motion was filed out of time because an Answer had previously been filed, but did note exceptions to this rule.
Alvarado then filed a Petition for Certiorari with the Court of Appeals which denied relief, finding no grave abuse of discretion by the RTC.
He subsequently filed a Petition for Review on Certiorari before the Supreme Court.

Respondents allege substantive legal interests: Capitol as the owner; individual members as shareholders and users enjoying benefits and possession rights; Ayala Land, Inc. and Ayala Hillside Estates as co-developers and having rights under a Memorandum of Agreement and easements relating to access roads.
Respondents claimed these rights were impaired by the tax sale, which they alleged to be irregular and prejudicial.

Whether the Court of Appeals erred in failing to find grave abuse of discretion in the RTC Judge’s denial of petitioner’s Motion to Dismiss despite its belated filing after the Answer.
Whether the grounds raised by petitioner in his Motion to Dismiss, though filed after the Answer, are valid and sufficient to warrant dismissal of respondents' complaint.
Whether respondents are real parties in interest with legal standing to assail the validity of the tax sale despite not holding ownership titles personally.
Whether petitioner’s grounds invoking lack of jurisdiction and failure to state a cause of action are tenable.
Whether respondents complied with the condition precedent of judicial deposit under Section 267 of the Local Government Code.