Case Digest (G.R. No. 137534)
Facts:
Efren Aquino and Angelica Aquino v. Quezon City, represented by its OIC, Brigido Simon, Anselmo O. Regis, Vicente N. Coloyan, as the Acting Register of Deeds of Quezon City, and Aida Linao, accompanied by her husband Pete Linao; and Solomon Torrado (represented by his heirs) v. Veronica Baluyot, Ruperto Baluyot, Corazon and Maximo Uy, DNX Development Corp., City Treasurer of Quezon City, Register of Deeds of Quezon City, and the Court of Appeals, G.R. Nos. 137534 and 138624, August 03, 2006, Supreme Court Second Division, Azcuna, J., writing for the Court.In G.R. No. 137534, petitioners Efren and Angelica Aquino owned a 612-square-meter lot in East Avenue Subdivision, Diliman (TCT No. 260878). They admit they deliberately withheld real property tax payments from 1975 to 1982 as a protest; as a consequence the City Treasurer auctioned the property on February 29, 1984 to Aida Linao, who later secured consolidation of title under a Land Registration Commission proceeding and obtained TCT No. 339476. The Aquinos claimed they learned of the sale only in April 1987 and filed an action for annulment of title, reconveyance and damages against Quezon City, the Treasurer, the Register of Deeds and Aida Linao before the RTC of Quezon City (Civil Case No. Q-51130). The RTC dismissed the complaint on February 25, 1995; the Court of Appeals affirmed on February 3, 1999.
In G.R. No. 138624, the subject was Lot 8 of TCT No. 21996 (407 sq. m., No. 20 North Road, Cubao) registered in the name of Solomon Torrado. The City Treasurer sent a Notice of Intent to Sell (Oct. 6, 1982) and a Notice of Sale (Dec. 10, 1982) to the address shown in the tax register ("Butuan City"), both of which were returned unclaimed; the lot was auctioned on February 23, 1983 and sold to Veronica Baluyot. Subsequent transfers and foreclosures ultimately placed the property in the name of DNX Corporation. Solomon Torrado (now deceased) — through his heirs — filed suit in the RTC (Civil Case No. Q-89-1563) on January 13, 1989; the RTC dismissed on March 12, 1992, and the Court of Appeals dismissed the appeal on March 24, 1998.
Both petitions assailed the validity of the tax-sales for failure to comply with the notice provisions of Presidential Decree No. 464 (P.D. No. 464), specifically Sections 65 and 73. The two petitions for review on certiorari were consolid...(Pro-only)
Issues:
- Did the City Treasurer comply with the notice requirements under Sections 65 and 73 of P.D. No. 464 so as to render the auction sales valid?
- Is mailing notices to the address shown in the tax rolls (constructive notice) sufficient, or is actual receipt by the taxpayer required?
- Was the City Treasurer negligent in repeatedly mailing notices to an insufficient address when the tax records contained a more complete address for the taxpayer?
- Were petitioners estopped from challenging the auction sales beca...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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