Case Digest (G.R. No. L-4033)
Facts:
Engracio Francia, the registered owner of a 328-square-meter residential lot with a two-story house in Barrio San Isidro, District of Sta. Clara, Pasay City, Metro Manila (TCT No. 4739 [37795]), failed to pay real estate taxes from 1963 to 1977. On October 15, 1977, the Republic of the Philippines expropriated a 125-square-meter portion of his property for ₱4,116.00, which was deposited with the Philippine National Bank and notice thereof received by Francia on September 30, 1977. For his ₱2,400.00 tax delinquency, the City Treasurer of Pasay City sold the remaining 203 square meters at public auction on December 5, 1977, under Section 73 of Presidential Decree No. 464, without Francia’s attendance as he was in Iligan City. Ho Fernandez emerged as the highest bidder, and a Final Bill of Sale was issued in his favor on December 11, 1978, both annotated on TCT No. 4739 (37795). On March 20, 1979, Francia filed a complaint to annul the auction sale (amended January 24, 1980). The PCase Digest (G.R. No. L-4033)
Facts:
- Ownership and Titling
- Engracio Francia is the registered owner of a 328 sqm residential lot with a two-story house in Barrio San Isidro (now Sta. Clara), Pasay City, under TCT No. 4739 (37795).
- On October 15, 1977, the Republic expropriated 125 sqm of this lot for P4,116.00, payment duly deposited with the Philippine National Bank (notice received September 30, 1977).
- Tax Delinquency and Auction Sale
- Francia failed to pay real estate taxes from 1963 to 1977, accruing P2,400.00 in arrears.
- Pursuant to PD No. 464, Section 73, the Pasay City Treasurer auctioned the remaining property on December 5, 1977; Ho Fernandez was the highest bidder.
- Procedural History
- Final Bill of Sale issued December 11, 1978 and annotated on TCT No. 4739.
- Francia filed a complaint to annul the sale on March 20, 1979 (amended January 24, 1980).
- Lower Court and Intermediate Appellate Court Decisions
- The Pasay RTC (April 23, 1981) dismissed the amended complaint, ordered issuance of a new TCT in favor of Ho Fernandez, and awarded P1,000 attorney’s fees.
- The Intermediate Appellate Court affirmed in toto, leading to this petition for review.
Issues:
- Legal Compensation
- Whether Francia’s P2,400.00 tax obligation was extinguished by legal compensation with the P4,116.00 expropriation payment.
- Notice of Auction Sale
- Whether the auction sale was void for lack of proper notice to Francia.
- Whether substantial compliance with notice requirements suffices when petitioner received and signed for the notice.
- Price Adequacy and Due Process
- Whether the P2,400.00 sale price for a 203 sqm lot was grossly inadequate to shock the conscience.
- Whether gross inadequacy, without fraud or collusion, renders a tax sale void or violates due process.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)