G.R. No. 207791 - City of Davao vs. Intestate Estate of Dalisay

The Intestate Estate of Amado S. Dalisay (the Estate) owned five (5) properties in Davao City, each covered by specific Transfer Certificates of Title (TCTs) and Tax Declarations.
These properties included: Lot 1, Lot 6, Lot 7, Lot 2 (all under Pcs-11-001298), and a building on Lot No. 26-B.

The properties were advertised for sale at a public auction scheduled on July 19, 2004, due to nonpayment of real estate taxes.
No bidders appeared at the auction; consequently, the City Government of Davao (the City) acquired the properties pursuant to Section 263 of Republic Act No. 7160 (Local Government Code or LGC), which allows the local treasurer to purchase such properties on behalf of the local government for want of bidder.

The City Treasurer issued the Declarations of Forfeiture for the five properties on September 13, 2005, over a year after the auction. These declarations set the redemption period within one (1) year from the declaration date.
The City annotated the Declarations of Forfeiture on the respective titles on October 3, 2005.

The Estate inquired about the redemption price and was furnished billing statements on September 11, 2006, with an aggregate total amounting to approximately P4,996,534.67.
On September 13, 2006, the Estate tendered payment of P5,000,000.00 to the City Treasurer but was refused acceptance.
The Estate then filed a Notice of Deposit of the amount with the Court and later filed an action for redemption, consignation, and damages against the City.

The Regional Trial Court (RTC) ruled in favor of the Estate, ordering the City to accept the payment as redemption and to issue a certificate of redemption. It also awarded actual damages and attorney's fees.
The Court of Appeals (CA) affirmed the RTC decision, citing the City’s delayed issuance of the Declaration of Forfeiture and the principle that redemption laws are liberally construed in favor of the property owner.

The City contended that the one (1) year redemption period should be reckoned from the date of the auction/sale (July 19, 2004), not from the declaration issuance (September 13, 2005).
It argued further that the late declaration was a ministerial misstep and should not estop the City from denying the Estate’s right to redeem beyond this period.
The City questioned the applicability of estoppel against the government and argued against application of provisions repealed by RA 7160.

Whether the one (1) year redemption period for forfeited tax delinquent properties purchased by the local government for want of bidder is reckoned from: