Case Summary (G.R. No. 208740)
Facts
CSDC, the registered owner of a lot in Makati City covered by Transfer Certificate of Title (TCT) No. 125211, accrued real property taxes amounting to PHP 1,458,199.85 from 1994 to 2006, which were unpaid. The City Treasurer of Makati issued a warrant for levy on April 7, 2006, leading to a public auction on May 24, 2006, where respondent Agojo emerged as the highest bidder, acquiring the property for PHP 2,000,000.00. The subsequent registration of a certificate of sale and the Final Deed of Conveyance occurred, prompting Agojo to seek a new certificate of title from the Regional Trial Court (RTC) after the redemption period expired.
Proceedings Before the RTC
CSDC and Prieto filed opposition to Agojo's petition in LRC Case No. M-5050, claiming they had not received the notice of tax delinquency or the warrant leading up to the auction sale. They argued that the City Treasurer failed to comply with various procedural requirements outlined in the LGC, including proper service of notices to them and the occupant of the property. On January 15, 2010, the RTC declared the auction sale invalid due to insufficient proof of compliance with legal requirements.
Appeal to the Court of Appeals
Dissatisfied with the RTC ruling, Agojo appealed, which led the Court of Appeals (CA) to initially uphold the RTC's decision on January 26, 2012. The CA reasoned that proper procedures concerning publication and service of notice had not been followed. After Agojo moved for reconsideration, on March 18, 2013, the CA reversed its earlier decision, affirming the auction sale's validity based on the presumption of regularity of official acts, asserting that the necessary procedural steps had been adequately met.
Grounds for Petition
Petitioners challenged the CA's decision on multiple grounds, including the inappropriate application of the presumption of regularity in tax delinquency cases, neglecting the procedural necessities prescribed by the LGC, shifting the burden of proof onto the petitioners, and failing to acknowledge the inadequate auction price relative to the property's fair market value.
Argument of the Parties
Petitioners argued that the presumption of regularity does not apply to administrative actions resulting in property deprivation, emphasizing that it is the responsibility of the purchaser to demonstrate adherence to the statutory requirements of a valid tax sale. Conversely, Agojo contended that he had fulfilled all necessary requirements, thus the burden lay with the petitioners to prove the invalidity of the auction sale.
The Court’s Ruling
The Court granted the petition, emphasizing that under the LGC, the burden is on the party asserting the validity of a tax delinquency sale to demonstrate compliance with all procedural requirements, particularly since such sales infringe on prope
...continue readingCase Syllabus (G.R. No. 208740)
Case Background
- This case involves a petition for review on certiorari filed by Corporate Strategies Development Corporation (CSDC) and Rafael R. Prieto against Norman A. Agojo.
- The petition seeks to review the March 18, 2013 Amended Decision and the August 15, 2013 Resolution of the Court of Appeals (CA) which reversed the January 15, 2010 Decision of the Regional Trial Court (RTC) of Makati City.
- The RTC had previously dismissed Agojo's petition for a new certificate of title for a parcel of land registered under CSDC, citing the nullity of the auction sale conducted by the City of Makati.
Facts of the Case
- CSDC is the registered owner of a 1,000 square meter parcel of land located in Makati City, covered by Transfer Certificate of Title (TCT) No. 125211.
- From 1994 to 2006, CSDC failed to pay real property taxes amounting to P1,458,199.85, resulting in a warrant issued by the City Treasurer on April 7, 2006.
- An auction sale was conducted on May 24, 2006, where Agojo was the highest bidder with a bid of P2,000,000.00, leading to the issuance of a certificate of sale later registered with the Registry of Deeds.
- After the expiration of the redemption period, Agojo filed a petition for a new certificate of title, which prompted opposition from CSDC and Prieto based on improper notification and procedural deficiencies in the auction sale.
Legal Proceedings
- CSDC and Prieto claimed they did not receive notice of tax delinquency or the warrant for the property, which was sent to an outdated address.
- They alleged several procedural violations under the Local Government Code (LGC), including:
- Failure to properly not