GR 193371; (December, 2016) (Digest)
G.R. No. 193371 . December 05, 2016
24-K PROPERTY VENTURES, INCORPORATED, PETITIONER V. YOUNG BUILDERS CORPORATION, RESPONDENT.
FACTS
This case stems from a CIAC Final Award ordering petitioner 24-K Property Ventures, Inc. to pay respondent Young Builders Corporation over ₱91 million for construction costs. The award became final and executory. To satisfy the judgment debt, the sheriff levied on petitioner’s properties, including two parcels of land on which a 27-storey condominium (Torre Venezia) stood, and sixteen condominium units in another building. An auction sale proceeded, and the properties were sold to respondent as the highest bidder for approximately ₱110.5 million. Petitioner moved to set aside the execution sale, alleging numerous procedural irregularities and gross inadequacy of price. The CIAC denied the motion, a ruling affirmed by the Court of Appeals.
ISSUE
The core issue is whether the execution sale conducted by the sheriff is valid and should be upheld despite the alleged procedural irregularities and the claim of gross inadequacy of the purchase price.
RULING
The Supreme Court denied the petition and upheld the validity of the execution sale. The legal logic rests on the presumption of regularity in the performance of official duties, which petitioner failed to rebut with clear and convincing evidence. The Court found that the sheriff substantially complied with the rules on execution. The service of the writ was validly effected on petitioner’s counsel after attempts to serve its officers failed. Notices of garnishment were served on several banks, and the levy on the real properties was properly recorded. The alleged irregularities, such as the timing of the notice of sale and the sheriff’s alleged failure to make a timely return, were deemed inconsequential and did not render the sale void. On the claim of gross inadequacy of price, the Court reiterated the settled doctrine that inadequacy of price, unless shocking to the conscience, is not a ground to nullify an execution sale, especially where, as here, the sale was conducted publicly. The mere fact that a 27-storey building stood on the levied lots did not invalidate the levy on the land itself. The intervenors’ claims were noted but were deemed separate from the validity of the execution proceedings against the judgment debtor. The Court emphasized that execution is the final stage of litigation, and its swift implementation is crucial to the administration of justice.