Title
IFC Service Leasing and Acceptance Corporation vs. Nera
Case
G.R. No. L-21720
Decision Date
Jan 30, 1967
In extrajudicial foreclosure, the court determined that a separate suit for possession is unnecessary post-redemption period if the judgment debtor remains in possession and no third-party rights are implicated.
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Case Digest (G.R. No. L-21720)

Facts:

  • The case involves an appeal from an order of the Court of First Instance of Rizal.
  • The petitioner, IFC Service Leasing and Acceptance Corporation, filed a verified petition for the extrajudicial foreclosure of a mortgage on the property of the spouses Venancio Nera and Rosa F. Nera.
  • The property, located at No. 9 Aleman Street, Quezon City, consisted of a house and lot.
  • The property was sold to the petitioner as the highest bidder for P28,451.77 after the period of redemption expired.
  • The petitioner was issued a new title for the property.
  • The respondent, Venancio Nera, filed a motion to set aside the writ of possession and the auction sale, claiming that the court had no jurisdiction to issue the writ and that the price at which the property was sold was grossly inadequate.

Issue:

  • (Unlock)

Ruling:

  • The court ruled in favor of the petitioner.
  • The court affirmed that a purchaser at a sheriff's sale of real property is not required to bring a separate suit for possession after the one-year redemption period has expired...(Unlock)

Ratio:

  • The court based its decision on Section 35 of Rule 39 of the Revised Rules of Court, which states that if no redemption is made within twelve months after the sale, the purchaser is entitled to a conveyance and possession of the property.
  • The court cited the case of Tan Soo Huat vs. Ongwico, where it was held that there is no law in the jurisdiction that obliges the purchaser at a sheriff's sale to bring a separate suit for possession after the redemption period has expired and after obtaining the sheriff's final certificate of sale.
  • The court emphasized that there is neither a legal ground nor a reason of public policy that precludes the court from ordering the sheriff to yield possession of the property purchased...continue reading

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