GR 37831; (November, 1981) (Digest)
G.R. No. L-37831 November 23, 1981
RESTITUTA V. VDA. DE GORDON, petitioner, vs. THE COURT OF APPEALS and ROSARIO DUAZO, respondents.
FACTS
Petitioner Restituta V. Vda. de Gordon owned two parcels of land in Quezon City. Due to unpaid real estate taxes from 1953 to 1963, the City Treasurer conducted a public auction sale on December 3, 1964, where respondent Rosario Duazo purchased the properties for P10,500. The certificate of sale was registered on December 28, 1964. Petitioner failed to redeem the properties within the statutory one-year period. Consequently, the City Treasurer executed a final deed of sale in favor of Duazo on January 4, 1966, which was registered on January 18, 1966. Duazo subsequently filed a petition for consolidation of ownership. Petitioner opposed, but her opposition failed to specifically deny the material averments regarding the regularity of the tax sale procedures.
ISSUE
The principal issues were: (1) whether the purchase price of P10,500 was so grossly inadequate as to invalidate the public auction sale; and (2) whether petitioner was still entitled to redeem the properties after the lapse of the redemption period.
RULING
The Supreme Court affirmed the Court of Appeals’ decision, upholding the validity of the tax sale and Duazo’s ownership. On the first issue, the Court ruled that mere inadequacy of price is not sufficient to annul a tax sale, especially when the law grants a right of redemption. The price, while lower than the combined assessed value of the land (P16,800) and improvements (a house assessed at P45,580 in 1961), was not so shocking to the conscience as to warrant judicial interference. Citing Velasquez vs. Coronel, the Court emphasized the doctrine that inadequacy is immaterial in tax sales because the right to redeem exists; a lower price theoretically makes redemption easier for the owner. The disparity here was not comparable to cases where the price was sixty times less than the assessed value.
On the second issue, the Court held that petitioner’s right to redeem had absolutely expired. The tax sale was governed by Section 40 of Commonwealth Act No. 470 (the Assessment Law), which provides a strict one-year redemption period from the date of sale. This period is mandatory and not subject to judicial confirmation, unlike foreclosure sales. Petitioner failed to redeem within that year or to make any tender of payment thereafter, and Duazo had been paying the real estate taxes since 1964. The Court found no legal basis to extend the redemption period, stressing that tax laws, while harsh, are necessary for the prompt collection of revenues essential to government operation.