Facts:
- A 612-square meter lot located in East Avenue Subdivision, Diliman, Quezon City.
- Originally owned by petitioner spouses Efren and Angelica Aquino under Transfer Certificate of Title (TCT) No. 260878.
- The petitioners admitted to withholding real property tax payments from 1975 to 1982 as a protest against the government of President Marcos.
- Due to nonpayment of taxes, the Quezon City local government, through its Treasurer’s Office, proceeded to sell the property at a public auction on February 29, 1984.
- Aida Linao, as the highest bidder, purchased the property, and later consolidated her title when a Regional Trial Court (RTC) granted her petition on September 25, 1985.
- Upon the court’s approval, the original TCT was cancelled and replaced by TCT No. 339476 in the name of Aida Linao.
- Petitioners Aquino discovered the auction sale in April 1987 when informed by individuals “squatting” on the property.
- They filed an action for annulment of title, reconveyance, and damages against the Quezon City local government, its officers (Treasurer and Register of Deeds), and Aida Linao.
- Their primary contentions included the claim that the local government sold the property without proper notice of tax default and that Aida Linao acted in bad faith by purchasing a property under such circumstances.
- The RTC of Quezon City dismissed the petition on February 25, 1995.
- The dismissal was subsequently affirmed by the Court of Appeals on February 3, 1999.
- A 407-square meter property situated at No. 20 North Road, Cubao, Quezon City, covered by TCT No. 21996 in the name of Solomon Torrado.
- Although TCT No. 21996 covers two lots, only Lot 8 is the subject of the controversy.
- Solomon Torrado paid taxes on the improvements of Lot 8 for certain years but not on the lot itself because the Treasurer’s Office could not locate the corresponding index card.
- For failure to pay taxes on Lot 8 from 1976 to 1982, the City Treasurer initiated the process by sending a Notice of Intent to Sell dated October 6, 1982, to Torrado’s address as per the tax register, which was simply stated as “Butuan City.”
- A subsequent Notice of Sale dated December 10, 1982 was also sent to the same address, and it too was returned unclaimed.
- The property was then auctioned publicly on February 23, 1983, and sold to Veronica Baluyot.
- Later, the property underwent several title transfers: it was mortgaged by Baluyot, foreclosed upon leading to another title cancellation (TCT No. 355133), and ultimately transferred to DNX Corporation under TCT No. N-162170.
- On January 13, 1989, Solomon Torrado commenced an action against the spouses Baluyot, Quezon City local government officers, and the Register of Deeds.
- The RTC dismissed the case on March 12, 1992, a decision later affirmed by the Court of Appeals on March 24, 1998.
- Petitioner Heirs, representing Solomon Torrado, raised issues regarding the sufficiency of notice sent by the City Treasurer.
- Both petitions questioned whether the procedures for serving notice—particularly under Sections 65 and 73 of P.D. No. 464—were properly complied with.
- They also discussed whether actual notice was required versus constructive notice, especially when notices were sent to addresses that were no longer valid or complete.
Issue:
Compliance with Notice Requirements Under P.D. No. 464
- Whether the Quezon City local government complied with the statutory notice requirements on the sale of tax-delinquent property by providing two distinct notices: a Notice of Tax Delinquency (Section 65) and a Notice of Sale (Section 73).
- Whether the method of sending notices—by registered mail to the address noted in the tax records—was sufficient even if no posting or publication was carried out.
Validity of Constructive Versus Actual Notice
- Whether the mere mailing of the Notice of Sale to a last known address, which they had abandoned, constituted proper actual notice.
- Whether they were estopped from questioning the absence of proper notice given their own admission of tax nonpayment.
- Whether construction of the notice provisions obligates the City Treasurer to use a complete and verifiable address instead of the minimal “Butuan City” provided by Solomon Torrado.
- Whether the evidence of the treasurer’s repeated mailing to the same insufficient address negates the validity of the notice served.
Interpretation of the Statutory Scheme Regarding Tax Collection
- Whether the notice of delinquency under Section 65, which is meant to serve as a prerequisite to various tax collection remedies, must be strictly complied with in all respects.
- Whether the absence of certain formalities (i.e., posting and publication) can be overlooked provided that sufficient personal notice was given in accordance with Section 73.
Ruling:
Ratio:
Doctrine: