GR 171033; (August, 2010) (Digest)
G.R. No. 171033 ; August 3, 2010
CITY MAYOR, CITY TREASURER, CITY ASSESSOR, ALL OF QUEZON CITY, and ALVIN EMERSON S. YU, Petitioners, vs. RIZAL COMMERCIAL BANKING CORPORATION, Respondent.
FACTS
Respondent Rizal Commercial Banking Corporation (RCBC) was the highest bidder at a foreclosure sale of properties owned by the spouses Naval on August 4, 1998, with the corresponding certificates of sale issued. Meanwhile, due to tax delinquency, the same properties were sold at a public auction by the Quezon City Treasurer on May 30, 2003, with petitioner Alvin Emerson S. Yu as the highest bidder. The Certificate of Sale of Delinquent Property to Yu was registered on February 10, 2004. On June 10, 2004, RCBC tendered payment to the City Treasurer to redeem the properties from the tax sale, but the tender was refused. RCBC filed a Petition for Mandamus.
The petitioners, Quezon City officials and Yu, argued that RCBC’s right to redeem had expired. They contended that the one-year redemption period under the Real Property Tax Code (P.D. No. 464) should be counted from the date of the tax auction sale on May 30, 2003. The Regional Trial Court initially denied RCBC’s petition but, upon reconsideration, granted it, ruling that the redemption period should be counted from the registration of the certificate of sale on February 10, 2004, making RCBC’s tender timely.
ISSUE
Whether the one-year period to redeem property sold at a tax delinquency auction should be reckoned from the date of the auction sale or from the date of registration of the certificate of sale.
RULING
The Supreme Court denied the petition and affirmed the RTC Decision. The Court held that the redemption period should be counted from the date of registration of the certificate of sale. While P.D. No. 464 was repealed by the Local Government Code ( R.A. No. 7160 ), the applicable law was the Quezon City Revenue Code of 1993, enacted pursuant to the Code. Section 14(a)(7) of this local ordinance explicitly provides that the owner or person having legal interest “shall have the right to redeem the property at any time within one (1) year from the date of sale.”
The Court applied the statutory construction principle that the word “sale” in redemption statutes can refer to the “perfect sale” consummated upon registration, not merely the auction proceedings. This interpretation aligns with the purpose of redemption laws, which is to give the owner a full opportunity to reclaim property. Counting the period from registration provides constructive notice to all interested parties, including lienholders like RCBC, and allows a definite and fair reckoning point. Since RCBC tendered payment on June 10, 2004, which was within one year from the February 10, 2004 registration date, its right of redemption was validly exercised. The City Treasurer was thus ordered to accept the payment and issue the certificate of redemption.