Facts:

• Prudencio De Jesus purchased a parcel of land from Pastor Lerma in 1907.
• The land was registered under the Torrens system, and De Jesus received a certificate of title in accordance with Act No. 496.
• The City of Manila assessed back taxes against De Jesus for a portion of the land that had not been taxed due to Lerma's incorrect declaration in 1901.
• Lerma inaccurately reported the land's area as 337,938.50 square meters instead of the actual size of 480,695.53 square meters, resulting in 142,767.03 square meters being untaxed from 1901 to 1910.
• In 1910, the city assessed these taxes against De Jesus, who paid P2,096.49 under protest.
• De Jesus subsequently filed a lawsuit to recover the amount, contending that he should not be responsible for taxes that were not assessed prior to his acquisition.
• The trial court ruled in favor of De Jesus, awarding him P1,649.82 plus costs, leading the City of Manila to appeal.

Issue:

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Ruling:

• The Supreme Court affirmed the lower court's decision, determining that De Jesus was not liable for back taxes that had not been assessed prior to his purchase.
• The court found th...(Unlock)

Ratio:

• The court's reasoning was grounded in Act No. 496, specifically Section 39, which indicates that a purchaser of registered land holds it free from all liens and encumbrances, except those noted on the title and taxes due within two years of transfer.
• Taxes must be levied or assessed before the purchase to be deemed due and payable.
• Since the taxes were first assessed in 1910, after De Jesus's purchase in 1907, they did not qualify as due and payable at t...continue reading