G.R. No. L-29906 January 30, 1976
RODOLFO GENERAL and CARMEN GONTANG, petitioners, vs. LEONCIO BARRAMEDA, respondent.

FACTS

Respondent Leoncio Barrameda mortgaged his land to the Development Bank of the Philippines (DBP) to secure a loan. Due to his failure to pay, the mortgage was extrajudicially foreclosed. A public auction was held on April 23, 1962, where DBP emerged as the highest bidder. The sheriff’s final deed of sale was executed on May 13, 1963, and DBP registered the sale and consolidated its ownership on September 2, 1963, leading to the issuance of a new title in its name. The following day, September 3, 1963, DBP sold the property to petitioners Rodolfo General and Carmen Gontang.
On November 20, 1963, prior to the annotation of the sale to the petitioners on the title, Barrameda offered to redeem the property from DBP, which refused. He subsequently filed a complaint and deposited the redemption price with the clerk of court. The trial court dismissed his complaint, ruling that the one-year redemption period under Section 31 of Commonwealth Act No. 459 (the DBP charter) commenced from the date of the auction sale (April 23, 1962) and had thus expired by April 24, 1963, making his November 1963 offer untimely. The Court of Appeals reversed this decision.

ISSUE

The principal issue is whether the one-year period of redemption for property foreclosed by the DBP under its charter begins to run from the date of the public auction sale or from the date of registration of the sale.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, ruling that the redemption period commenced from the registration of the sale. The Court rejected the petitioners’ argument that the specific wording of Section 31 of Commonwealth Act No. 459 (“from the date of the auction sale”) should control over general principles. It held that for registered land under the Torrens system, the operative act that conveys title and provides constructive notice to the world is the registration of the deed of sale. This principle, established in prior jurisprudence such as Gonzales v. PNB and Salazar v. Court of Appeals, applies uniformly unless a statute explicitly provides otherwise. The Court found no compelling legislative intent in the DBP charter to deviate from this established rule.
Consequently, the one-year period started on September 2, 1963, the date of registration. Barrameda’s offer to redeem on November 20, 1963, was therefore well within the legal period. Since the redemption was validly exercised, the subsequent sale by DBP to the petitioners was rendered null and void. The Court deemed it unnecessary to resolve the ancillary issue of whether the petitioners were purchasers in good faith, as the valid redemption extinguished DBP’s title and its capacity to convey the property.