G.R. No. 132768 September 9, 2005
Jaime B. Biana, Petitioner, vs. George Gimenez, Respondent.

FACTS

Respondent George Gimenez was a judgment debtor in a labor case. To satisfy a monetary award of approximately ₱5,248.50, Deputy Sheriff Renato Madera levied and auctioned four parcels of Gimenez’s land, with an aggregate area exceeding 74 hectares. The properties were sold at public auction to the judgment creditor, Santos B. Mendones, for ₱8,908.50. Gimenez claimed he was not properly notified of the sale. To redeem the properties within the one-year period, Gimenez approached Provincial Sheriff Manuel Garchitorena, who computed the redemption price. Gimenez issued checks payable to Sheriff Garchitorena, who issued an official receipt acknowledging full payment of the judgment obligation months before the redemption period expired. However, Deputy Sheriff Madera later claimed an unpaid balance for publication fees and, despite Gimenez’s protest that he had paid the publisher directly, executed a Definite Deed of Sale in favor of Mendones after the redemption period. Mendones later assigned his rights to petitioner Jaime B. Biana for ₱1,000,000.

ISSUE

Whether respondent Gimenez validly effected the redemption of the properties sold at the execution sale.

RULING

Yes, the Supreme Court affirmed the Court of Appeals and held that a valid redemption was made. The legal logic centers on the nature of redemption and the act of payment. Redemption is the act of repurchasing a property after a judicial sale by paying the redemption price within the prescribed period. The Court ruled that Gimenez’s payment to the Provincial Sheriff, who was acting within the scope of his authority as the officer charged with implementing the writ of execution, constituted valid payment that effectively stopped the running of the redemption period. The issuance of an official receipt by Sheriff Garchitorena was a conclusive acknowledgment of full settlement. The subsequent claim by Deputy Sheriff Madera for additional publication fees, which Gimenez disputed having paid directly to the newspaper, did not invalidate the prior completed redemption. The sheriff’s receipt was deemed an authoritative declaration that the obligation was satisfied. Consequently, the Definite Deed of Sale issued to Mendones was void, and Gimenez was entitled to a deed of redemption. The Court also upheld the award of moral damages and attorney’s fees against petitioner Biana, finding that he pursued litigation over a multimillion-peso property despite knowledge of the minimal original claim and the completed redemption.