Facts:

The case involves Samuel M. Alvarado as the petitioner and several respondents, including Ayala Land, Inc., Ayala Hillside Estates Homeowners' Association, Inc., and various individuals, including Alexander P. Aguirre and Ricardo F. De Leon, among others. The dispute arose from a tax sale conducted on December 13, 2007, where a 15,598-square-meter parcel of land in Quezon City, which was owned by the Capitol Hills Golf and Country Club, Inc., was auctioned due to unpaid real estate taxes totaling approximately P1,857,136.89. Alvarado emerged as the highest bidder, securing the property for P2,600,000.00.

Subsequently, on December 7, 2010, the respondents filed a complaint against Alvarado and others in the Quezon City Regional Trial Court, questioning the legitimacy of the tax sale. They alleged that the sale price was grossly inadequate—amounting to only a fraction of the assessed and zonal values of the property—and raised concerns about procedural deficiencies, including

...

Facts:

Background and Transaction Details

• Capitol Hills Golf and Country Club, Inc. owned a 15,598‑square‑meter parcel in Quezon City covered by TCT No. N‑253850, which was assessed and zoned at high values.
• On November 16, 2007, the property was levied on account of unpaid real estate taxes and associated penalties.
• On December 13, 2007, the parcel was subjected to a tax delinquency sale, and petitioner Samuel M. Alvarado emerged as the highest bidder for an amount of P2,600,000.00, which was significantly lower than the assessed, market, and zonal values.

Initiation of Litigation and Pleadings

• Respondents (including Ayala Land, Inc., Ayala Hillside Estates Homeowners’ Association, Inc., and several individuals) filed a complaint challenging the validity of the tax sale on several grounds, alleging anomalies such as:
• The sale of the entire parcel instead of only the portion necessary to cover the tax delinquency (net of penalties).
• Non-compliance with statutory notice requirements under the Local Government Code and the Quezon City Revenue Code.
• The issuance of the Final Bill of Sale before the expiration of the redemption period.
• In response, petitioner Alvarado filed his Answer with a compulsory counterclaim and asserted several affirmative defenses:
• Lack of jurisdiction due to non-compliance with the mandatory judicial deposit as required by Section 267 of the Local Government Code.
• Failure of respondents to state a cause of action, based on the contention that they were not the registered owners of the auctioned property and had no authority from such owner.
• Lack of subject matter jurisdiction, arguing that respondents had not shown any real, substantial legal rights or interest in the property.

Subsequent Motions and Orders

• Petitioner subsequently filed a Motion to Dismiss on April 14, 2011, which essentially reiterated the affirmative defenses previously set forth in the Answer.
• Presiding Judge Tita Marilyn Payoyo-Villordon of the Regional Trial Court denied the Motion to Dismiss on September 6, 2011, ruling that filing an Answer barred the subsequent independent motion.
• A Motion for Reconsideration was also filed and denied on January 6, 2012.
• Petition for Certiorari was later elevated to the Court of Appeals and finally brought before the Supreme Court challenging the denial of the Motion to Dismiss and alleging grave abuse of discretion.

Statutory and Procedural Context

• The procedure for filing motions to dismiss is governed by the 1997 Rules of Civil Procedure, specifically Rule 16, Section 1, which stipulates that such motions must be filed before or within the time for filing an Answer.
• Rule 9, Section 1 clarifies that defenses not pleaded in an Answer are deemed waived, although those pleaded remain valid even if reiterated later.
• Section 267 of the Local Government Code sets the condition for instituting an action assailing the validity of a tax sale, particularly the mandatory judicial deposit requirement.

Issues Pertaining to Property Interest

• Respondents contended that despite petitioner's challenge, they were the real parties in interest by virtue of their membership, shareholding, and co-developer status in Capitol, thus claiming an inherent right to protect the value and integrity of the property.
• The controversy included whether the sale of the entire parcel improperly affected their rights and whether the legal procedures adopted in the tax sale were in strict compliance with statutory requirements.

Issue:

Procedural Validity of the Motion to Dismiss

• Whether filing a Motion to Dismiss after submitting an Answer—wherein the relevant defenses were already pleaded as affirmative defenses—should be considered by the court.
• Whether such repetition of defenses amounts to a waiver or constitutes a permissible reiteration under the Rules of Civil Procedure.

Jurisdictional Challenges Raised by the Petitioner

• Whether the failure to comply with the mandatory judicial deposit (as required by Section 267 of the Local Government Code) deprives the court of jurisdiction over the case.
• Whether the allegation regarding respondents not being the registered owners (thus lacking legal capacity and standing) is sufficient to dismiss the action.

Substantive Validity of Respondents’ Claims

• Whether respondents, as real parties in interest, have satisfactorily alleged their causes of action despite the purported defects identified in the petitioner’s Motion to Dismiss.
• Whether the alleged procedural irregularities in the tax sale (such as improper notice postings and premature issuance of the Final Bill of Sale) warrant the invalidation of the sale.

Grave Abuse of Discretion

• Whether the Court of Appeals and trial court erred in not finding grave abuse of discretion in the denial of petitioner’s Motion to Dismiss and Motion for Reconsideration.
• Whether the decision to treat the belated Motion to Dismiss as merely reiterative (and thus not a basis for dismissal) was appropriate.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)