G.R. No. 220440 - Salva vs. Magpile

In 1968, respondent Ildefonso P. Magpile acquired a 262‑square‑meter parcel of land in Makati City.
His title, Transfer Certificate of Title (TCT) No. 215195, was registered on February 19, 1968, with the postal address “2118 Apolinario, Makati, Rizal.”
Magpile transferred ownership to himself and resided in the subject property.

On June 30, 1980, Magpile filed a Sworn Statement with the Makati Municipal Assessor declaring the current and fair market value of his property.
In that statement, he provided “1772 Evangelista, Bangkal, Makati, M.M.” as his postal address.

Magpile failed to pay real property taxes from 1998 up to 2006.
The City Treasurer sent billing statements, notices of tax delinquency, and warrants of levy to the address “2118 Apolinario St., Bangkal, Makati City.”
On May 24, 2006, the property was sold at a public auction for P200,000.00 to petitioner Katherine Rose Salva, who was the highest bidder.

On March 5, 2008, through his daughter Ma. Socorro Magpile-Del Rosario as attorney‑in‑fact, Magpile filed a petition to declare the auction sale null and void and to cancel the Certificate of Sale issued in favor of Salva.
Magpile argued that he did not receive the notices and the warrant of levy because they were sent to his former address, and he relied on a Certification from the Barangay Captain of Pio del Pilar stating that “2118 Apolinario Street” had been changed/superseded.

During pre‑trial, the parties stipulated relevant facts regarding the tax records and addresses, with Salva admitting the authenticity of documents such as the TCT, billing statements, tax delinquency notice, warrants of levy, notice of public auction, and the Certification.
Magpile maintained that the notices were sent to an erroneous and outdated address, and that he never received them, which was a violation of duly prescribed due process.
Salva contended that the City Treasurer enjoyed the presumption of regularity and argued that the notices, even if sent by registered mail, were sufficient, emphasizing that Magpile had not effectively contradicted the use of multiple addresses.

Whether the auction sale conducted on May 24, 2006 validly conferred title to the petitioner.

Compliance with Statutory Requirements under the Local Government Code (LGC)

Whether the City Treasurer complied with the provisions of Section 258 of the LGC in sending the notices and the warrant of levy.
Whether the notices and warrant of levy—sent to Magpile’s former address rather than his current one—satisfied the requirements for due process.

Whether the notice of levy was actually received by Magpile (or his authorized representative) as required by law.