Case Summary (G.R. No. 255212)
Factual Background
In May 2011, the City Treasurer of Cebu published a notice of sale for tax-delinquent properties, including a lot owned by the heirs of Benigno Sumagang. The respondent participated in the auction, securing the property for PhP 295,994.89. On May 22, 2012, one of the heirs, Anita Sumagang, intended to redeem the property and was advised to provide identification. On May 28, her initial redemption attempt failed due to lack of identification. However, she returned with proof of her identity on May 30, 2012, and successfully redeemed the property. The City Treasurer later issued a Certificate of Redemption, which was contested by the respondent, leading to a petition for mandamus and damages.
RTC Ruling
The Regional Trial Court (RTC) granted respondent's petition for mandamus, ruling that the heirs of Benigno failed to redeem the property within the one-year redemption period. The RTC concluded that the redemption deadline expired on May 26, 2012. Therefore, the right of redemption was lost, and ownership was transferred to the respondent, making the issuance of a deed of conveyance a ministerial duty for the petitioner.
CA Ruling
The Court of Appeals affirmed the RTC ruling, clarifying that according to Section 262 of RA 7160, if the property is not redeemed within one year, the local treasurer must execute a deed conveying the property to the purchaser. The CA ruled that the heirs’ redemption was indeed invalid since the one-year period expired before their payment on May 30, 2012. The CA also highlighted that the City Treasurer acted reasonably in requiring proof of identity.
Issues Raised
Petitioner contended that:
- The CA erred in allowing mandamus without the heirs being part of the case.
- The CA incorrectly interpreted Section 261 regarding completion of the redemption.
- The CA failed to consider the petitioner's liberal policy in applying the redemption period.
Court's Ruling
The Supreme Court granted the petition, reversing the CA decision and dismissing the mandamus petition. It emphasized that redemption must comply with statutory requirements. In distinguishing between strict adherence to law versus strict adherence to procedural rules, the court underscored the need for substantial compliance due to the contextual earnestne
...continue readingCase Syllabus (G.R. No. 255212)
Background of the Case
- The case involves a Petition for Review on Certiorari filed by the City of Cebu, represented by the City Treasurer, challenging the decisions of the Court of Appeals that affirmed the Regional Trial Court's ruling.
- The primary issue revolves around the right of redemption by the heirs of Benigno Sumagang concerning a property sold at a tax delinquency auction, which was subsequently won by Alta Vista Golf and Country Club, Inc.
Factual Antecedents
- On May 13, 2011, the City Treasurer published a "Notice of Sale of Tax Delinquent Properties," including Lot No. 4 PSU-192448 owned by the heirs of Benigno Sumagang.
- Alta Vista participated in the auction held on May 27, 2011, winning the bid of PhP 295,994.89.
- Following the auction, a Certificate of Sale was issued to Alta Vista.
- The heirs of Benigno, particularly Anita Sumagang, attempted to redeem the property but faced issues regarding the proof of their identity.
- A Certificate of Redemption was issued on June 4, 2012, after Anita provided the necessary documentation, but Alta Vista contested the validity of this redemption.
Ruling of the Regional Trial Court (RTC)
- The RTC ruled in favor of Alta Vista, granting their petition for mandamus and damages.
- It ordered the City Treasurer to issue the final deed of conveyance to Alta Vista and to cancel the Certificate of Redemption issued to the heirs.
- The RTC conc