Title
Velayo vs. Ordoveza
Case
G.R. No. L-9061
Decision Date
Nov 18, 1957
A property auctioned for unpaid taxes was invalidated due to discrepancies in the property description and the City Treasurer's lack of authority.

Case Summary (G.R. No. L-9061)

Property Details and Tax Sale Mechanics

The property in question is described as a parcel of land with an area of 99.40 square meters. However, the Ordinance that describes the property in the tax sale does not match the descriptions in the Ordovezas' Transfer Certificate of Title No. 79178, which notes the property comprises two lots with a total area of 94.80 square meters and 2.30 square meters, respectively. The City Treasurer conducted the auction for tax delinquency on October 29, 1949, resulting in Velayo winning the bid.

Procedural Developments Post-Sale

Following the tax sale, the Ordovezas were unaware of the proceedings until November 20, 1950, when Fernando Ordoveza attempted to pay the back taxes. At that point, he was informed of the sale and subsequently offered to reimburse Velayo's payment with interest. Velayo did not respond to Ordoveza’s offer and instead proceeded to secure a certificate of sale from the City Treasurer on December 4, 1950. The Ordovezas attempted to redeem the property by sending payment to the City Treasurer, which the office accepted merely as a deposit, asserting that the redemption period had expired.

Denial of Velayo’s Petition

Velayo then filed for the registration of the property, asserting ownership based on the September 12, 1951 deed executed by the City Treasurer. The Ordovezas opposed the registration, citing discrepancies in property descriptions and arguing that they had already paid the relevant taxes. On February 22, 1955, the Court of First Instance of Manila upheld the Ordovezas’ opposition and dismissed Velayo’s registration petition.

Legal Provisions Under Review

The key legal framework under review stems from Republic Act No. 409, which stipulates the role of the City Assessor and Collector in tax delinquency cases. This act delineates responsibilities relating to tax collection and property sales, stating that the City Assessor—not the City Treasurer—should oversee the processes of tax sale auctions, notifications, and the execution of sale deeds.

Decision Rationale

The ruling explained that the notice of sale and subsequent actions taken by the City Treasurer were invalid since he lacked the authority to conduct such sales or issue deeds of sale under the law. This error c

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