Case Summary (G.R. No. L-19545)
Background of the Case
The case arises from an appeal by the Philippine Suburban Development Corporation against the disallowance of its request for a refund of real estate tax amounting to P30,460.90, which it paid to the Provincial Treasurer of Bulacan. The facts indicate that on June 8, 1960, the President of the Philippines authorized the People's Homesite and Housing Corporation (PHHC) to acquire land for relocating squatters. Subsequent to this, the PHHC and PSDC, which owned the land in question, executed a contract for sale.
Execution of Sale and Payment Terms
On December 29, 1960, PSDC executed a Deed of Absolute Sale, conveying two parcels of land to PHHC for P3,386,223. The sale terms included a portion of the payment being retained to clear existing liens on the property, while the balance was to be paid once the PHHC secured funds from the Government Service Insurance System (GSIS). The deed, however, was not registered until March 14, 1961. Prior to this, the PHHC had taken possession of the property in early June 1960 to commence development for squatters.
Dispute Over Tax Liability
A controversy arose when the Provincial Treasurer of Bulacan insisted that PSDC remain liable for property taxes due for the year 1961, despite the execution of the deed. PSDC contended that it had ceased to be the owner once the sale was executed. The Secretary of Finance ultimately denied PSDC's request for a tax refund, asserting that ownership and tax liability continued with PSDC until the deed was officially registered.
Legal Arguments Presented
In its appeal, PSDC argued that the execution of a public instrument constituted delivery of ownership, citing Article 1498 of the Civil Code. Conversely, the Auditor General's office reasoned that until the deed was registered under the Land Registration Act, PSDC remained the legal owner of the property. The response stressed that the original conditions of the contract necessitated specific approvals before finalizing the transfer of ownership.
Court's Analysis
The Court found merit in PSDC's arguments, noting that the Presidential approval and subsequent actions indicated that the intent was to treat the sale as completed. The Court underscored that under the Civil Code, the execution of the deed equated to delivery unless explicitly stated otherwise, which was not the case her
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Case Overview
- The case involves the Philippine Suburban Development Corporation (petitioner) appealing a decision by the Auditor General, Pedro M. Gimenez (respondent), which disallowed a request for a refund of real estate tax amounting to P30,460.90.
- The tax was paid to the Provincial Treasurer of Bulacan after the petitioner sold property to the People's Homesite and Housing Corporation (PHHC) for the purpose of resettling squatters and flood victims.
Background Facts
- On June 8, 1960, the President of the Philippines approved the acquisition of the Sapang Palay Estate in Sta. Maria, Bulacan, for the relocation of squatters.
- The project was financed through the flotation of bonds under the charter of the PHHC.
- The PHHC passed Resolution No. 700 on June 10, 1960, authorizing the purchase of the property at P0.45 per square meter, contingent upon several conditions including the approval of the purchase price by the President.
- The Deed of Absolute Sale between the petitioner and the PHHC was executed on December 29, 1960, but was not registered until March 14, 1961.
Issues Raised
- The petitioner argued that it ceas