G.R. No. L-23691 - Reyes vs. Noblejas

The case involves a dispute over the registration of a Deed of Sale and an Affidavit of Consolidation of Ownership presented by petitioner Arsenio Reyes.
The respondents are Antonio Noblejas in his official capacity as Land Registration Commissioner and Jose Santos in his capacity as the Register of Deeds of Rizal.

The properties involved are registered under Transfer Certificates of Titles Nos. 18230, 18231, 18232, 18233, and 18234, owned by spouses Leonardo Gamboa and Aurora L. Cariaga.
These properties were mortgaged to the Philippine National Bank.
Upon the mortgagors’ failure to settle the indebtedness upon maturity, the properties were foreclosed extrajudicially under Act No. 3135, as amended by Act No. 4118.

On February 6, 1963, the Provincial Sheriff of Rizal sold the foreclosed properties at a public auction, with Arsenio Reyes emerging as the highest bidder for the sum of P6,010.00.
The sheriff issued the corresponding certificate of sale on February 21, 1963, setting the redemption period at one (1) year from the date of sale.
It is noted that the duplicate of the certificate of sale was not registered in the Registry of Deeds, and a copy attached to the Affidavit of Consolidation of Ownership was not entered in the Primary Entry Book for Act 496.

On February 10, 1964, petitioner presented an Affidavit of Consolidation of Ownership (executed on February 8, 1964) and a Deed of Sale executed by the Philippine National Bank in favor of Arsenio Reyes for registration.
The Register of Deeds of Rizal denied the registration of these documents on the ground that the redemption period had not yet expired.
The Register of Deeds based his decision on the legal principle that for registered land, the redemption period runs from the date of registration of the certificate of sale, not from the date of sale.

Petitioner Arsenio Reyes contended that Section 6 of Act No. 3135, as amended, mandates the redemption period to begin from the date of the auction sale.
The Land Registration Commissioner, however, argued that the relevant law for registered land—incorporating sections of Rule 39 of the Revised Rules of Court and provisions of Act 496—requires that the certificate of sale be registered, and only then does the redemption period begin.
Supporting legal precedents (e.g., Salazar v. Meneses) were cited to reinforce that registration is the operative act for conveyance and that the statutory redemption period must be computed from the registration date.

The Land Registration Commissioner’s resolution mandated the denial of registration of the Deed of Sale and the Affidavit of Consolidation of Ownership because the certificate of sale had not yet been registered.
A motion for reconsideration of this resolution was filed but subsequently denied, prompting the petition for review by Arsenio Reyes.

Whether the period of redemption for properties sold at public auction pursuant to an extrajudicial foreclosure under Act No. 3135 (as amended by Act No. 4118) should be reckoned from the date of the execution of the certificate of sale by the sheriff or from the date of its registration in the Office of the Register of Deeds.

Whether the principle established in prior decisions (e.g., Salazar v. Meneses, Garcia v. Ocampo) regarding the registration of the certificate of sale in the Torrens system should be applied to foreclosure sales.
Whether the absence of any third-party claimants or redemptioners could justify the application of a different rule, thereby making registration unnecessary for the sale to take effect between the immediate parties.