Title
Real Property Documents Require Tax Payment
Law
Republic Act No. 456
Decision Date
Jun 8, 1950
Republic Act No. 456 prohibits the registration of real property documents without full tax payment, requiring evidence of payment within fifteen days and an extra copy to be sent to the assessor, ensuring proper tax collection and record-keeping.

Coverage: real property documents covered

  • Section 1 bars registration of any voluntary document by which real property or an interest therein is sold, transferred, assigned, mortgaged or leased if real estate taxes are delinquent.
  • The bar applies to registration in the registry of property (i.e., the register of deeds system for property registration).
  • Section 2 applies to every document of transfer or alienation of real property that is filed with the Register of Deeds.

Substantive rule: tax-payment requirement

  • Section 1 requires that real estate taxes levied and actually due on the real property must be fully paid before a covered voluntary document may be registered.
  • The requirement operates as a registration precondition tied to the tax status of the real property for real estate taxes that are levied and actually due.
  • Section 1 recognizes a qualifying evidentiary method through a tax-status certification by the treasurer.

Evidence of payment and cancellation rule

  • Section 1 requires that evidence of full payment be presented within fifteen days from the date of entry of the document in the primary entry book of the register of deeds.
  • If the required evidence is not presented within fifteen days, Section 1 provides that the entry shall be deemed cancelled.
  • Section 1 allows a certificate of the provincial, city or municipal treasurer showing the real property is not delinquent in taxes as sufficient evidence for purposes of the Act.

Additional filing-and-notification duty

  • Section 2 requires that every document of transfer or alienation of real property filed with the Register of Deeds be accompanied with an extra copy of the document.
  • Section 2 directs that the Register of Deeds must transmit the extra copy to the city or provincial assessor.
  • Section 2 imposes this transmission duty irrespective of whether said document has been registered or denied registration.
  • Section 2 provides a limitation: failure to furnish the Register of Deeds with the extra copy shall not invalidate an otherwise valid agreement.

Penalties and sanctions; separability; repeals

  • Republic Act No. 456 provides a registration bar and an entry-cancellation mechanism for failure to present evidence within fifteen days under Section 1.
  • Republic Act No. 456 imposes an evidentiary certification requirement under Section 1 for non-delinquency.
  • Republic Act No. 456 contains no separate penalty or fine provisions beyond the registration and cancellation consequences expressly provided in Section 1.

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