G.R. No. L-11595; March 2, 1918
CATALINA INFANTE, plaintiff-appellant, vs. JUSTO TOLEDO and VICENTA SANTIONG, defendants-appellees.

FACTS:
Catalina Infante filed an action to recover possession of a parcel of abaca land in Silang, Cavite, and to claim damages. She alleged that she mortgaged the land to the defendants in April 1908 for P100, without a fixed period, on the condition that the land would be returned upon payment. In 1911, she tendered payment, but the defendants refused to accept it and return the land. The defendants, in their answer, claimed ownership by virtue of a purchase at a public auction conducted by the provincial sheriff pursuant to an execution issued against Infante. The records showed that Infante and another were sued by defendant Vicenta Santiong before the justice of the peace court for a money debt. Judgment was rendered against them, and after it became final, the subject land was attached and sold at public auction to Santiong. The sheriff executed a final deed of sale after the redemption period expired. Infante, in her amended complaint, sought to annul this sheriff’s sale. The Court of First Instance of Cavite upheld the validity of the judicial proceedings and the sheriff’s sale, absolving the defendants. Infante appealed, challenging the legality of the proceedings in the justice of the peace court and the consequent execution sale.

ISSUE:
Whether the proceedings in the justice of the peace court and the subsequent execution sale of the land were valid, thereby vesting lawful title in the defendant-purchaser and barring the plaintiff’s action for recovery of possession and damages.

RULING:
The Supreme Court affirmed the judgment of the lower court. The Court held that the proceedings before the justice of the peace were regular and in accordance with law. The plaintiff was duly summoned, declared in default for non-appearance, and properly notified of the judgment. The execution and the sheriff’s sale were also conducted in compliance with legal requirements, including proper publication of the notice of sale. Consequently, the defendant Vicenta Santiong acquired a valid title to the land through the judicial sale. The plaintiff’s action, which was essentially a collateral attack on the judgment in the prior case, could not prosper. A judicial sale, made under the authority of a competent court and in conformity with the law, transfers absolute title to the purchaser. The Court found no error in the lower court’s decision and affirmed it with costs against the appellant.