Case Digest (G.R. No. 173829)
Facts:
Valbueco, Inc. v. Province of Bataan, G.R. No. 173829, June 10, 2013, Supreme Court Third Division, Peralta, J., writing for the Court. Petitioner Valbueco, Inc. was the registered owner of eight parcels of land in Saysain, Bagac, Bataan (TCT Nos. 47377–47382, 47385–47386), totaling about 1,862,123 sq. m. and assessed at P1,364,330.00 (1994). Because of unpaid real property taxes, those parcels were sold at public auction in 1987 or 1988, the Province of Bataan being the winning bidder for P70,762.90. Years later, on March 29, 1995, petitioner filed a complaint to nullify the tax sale and the consolidation of title in favor of the Province and to reconvey possession, alleging among others: failure to distraint personal property first; failure to annotate the distraint; lack of publication/posting and failure to serve notice of sale; and unlawful consolidation of title.Respondents denied the allegations and pleaded that collection under Presidential Decree No. 464 (PD 464, Real Property Tax Code) authorizes alternative and cumulative remedies (citing Sec. 67) and that the statutory requirements for sale were complied with; they further alleged petitioner never attempted to pay or redeem the property. Petitioner later amended its complaint (Sept. 10, 1998) to implead the Secretary of the Department of Agrarian Reform (DAR) and 85 agrarian beneficiaries after the subject lots were placed under CARP and CLOAs were issued; petitioner relied on Luz Farms v. Secretary of the DAR to seek cancellation of CLOAs.
Procedurally, the trial court initially dismissed the Amended Complaint on September 29, 1999 but, on reconsideration (Feb. 8, 2000), held that even if it lacked jurisdiction over DAR-related relief, it retained jurisdiction to adjudicate the validity of the tax sale and transfer of title to the Province. After trial on the merits the Regional Trial Court (RTC), Branch 1, Balanga City, Bataan, rendered judgment on August 19, 2003 dismissing the complaint for lack of merit and ordering a refund of P133,033.90 deposited by petitioner; it also ordered P50,000 attorneys’ fees (later deleted by appellate court). Petitioner appealed to the Court of Appeals (CA), which on October 24, 2...(Pro-only)
Issues:
- On procedural grounds, are the questions raised by petitioner predominantly factual issues such that the Supreme Court, in a Rule 45 petition, should not reexamine them?
- Substantively, were the tax sale and the consolidation/transfer of title in favor of the Province of Bataan invalid for failure to comply with the procedural requirements of PD No. 464 (notice, publication, posting, distraint of personal property), and did petitioner present preponderan...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)