G.R. No. 253355 . November 08, 2023
DAVIDSON GO, PETITIONER, VS. SPOUSES HENRY AND JANET KO, RESPONDENTS.

FACTS

Petitioner Davidson Go purchased a parcel of land in Quezon City at a public auction due to the previous owner’s tax delinquency. After the one-year redemption period lapsed without redemption, the City Treasurer’s Office issued a Final Bill of Sale in Go’s favor. Go then filed a petition for consolidation of title. Respondents, Spouses Henry and Janet Ko, opposed, claiming ownership of the property by virtue of an undated and unnotarized Deed of Absolute Sale from the original owner, Lexus Development, Inc. They asserted they had resided on the property since 1996 and had validly redeemed it by paying the redemption price to the City Treasurer’s Office within the statutory one-year period.
The Regional Trial Court (RTC) ruled in favor of Go, ordering the issuance of a new title in his name. The RTC held the Spouses Ko’s redemption was invalid because they failed to present proof of authority from the registered delinquent owner, Lexus, to redeem the property. The Court of Appeals (CA) reversed the RTC. The CA found the Deed of Absolute Sale valid and held that the Spouses Ko’s long-term possession vested them with a legal interest sufficient to exercise the right of redemption under the Local Government Code.

ISSUE

Whether the Spouses Ko validly exercised the right to redeem the property sold at a tax delinquency auction.

RULING

Yes, the Spouses Ko validly redeemed the property. The Supreme Court affirmed the CA decision, emphasizing the liberal construction of redemption laws. The right of redemption under Section 261 of the Local Government Code ( Republic Act No. 7160 ) is granted to “the owner of the delinquent real property or person having legal interest therein, or his representative.” The Court ruled that the Spouses Ko, as possessors of the property since 1996 under a claim of ownership via a Deed of Absolute Sale, qualify as persons with a legal interest. This interest is a real, material, and substantial interest in the property, which is directly affected by its loss.
The Court rejected Go’s argument that the Spouses Ko needed to present formal proof of authority or ownership to the treasurer at the time of payment. The law imposes no such procedural requirement for the redemptioner to prove their interest to the local treasurer as a condition for a valid tender of payment. The payment itself, made within the one-year period and officially receipted in the name of the delinquent taxpayer, Lexus, constituted a valid redemption. This act invalidated the certificate of sale issued to Go. The Court clarified that any internal office practice requiring documentary proof is not a legal prerequisite that can defeat the substantive right of redemption. The purpose of redemption laws is to give the owner or interested party a chance to recover their property, and this right is not to be defeated by overly strict technicalities.