G.R. No. L-13029; June 30, 1959
MARIA A. GARCIA, plaintiff-appellant, vs. JESUS OCAMPO, ROSARIO OCAMPO, LAO KING HING, and THE HEIRS OF RAMON RIVERA, defendants-appellees.

FACTS

Maria A. Garcia obtained a judgment against Jacinta Rivera (owner of one-half of a parcel of land covered by TCT No. 28709) for P1,630.80. A writ of execution was issued, and the Manila Sheriff levied on Jacinta Rivera’s rights to the land in 1932. This levy was registered with the Register of Deeds. The sheriff then sold the one-half portion at public auction to Garcia in 1932 and issued a final deed of sale in 1933. From 1933 to 1956, Garcia possessed the property and collected rentals exceeding P5,000. On March 20, 1956, Garcia filed a complaint against the defendants (Jesus Ocampo, et al.) alleging that they illegally entered the land and executed a lease contract with Lao King Hing without her permission. She sought to have the sheriff’s sale noted on the title, cancel TCT No. 28709, issue a new title for her one-half share, declare the lease void, and award damages. The defendants moved to dismiss on grounds of prescription, failure to state a cause of action, and litis pendentia. The trial court dismissed the complaint.

ISSUE

1. Whether Garcia’s cause of action to enforce the sheriff’s sale and seek titling had prescribed.
2. Whether the complaint stated a cause of action, particularly regarding the registration requirements for the sheriff’s sale.

RULING

The Supreme Court AFFIRMED the dismissal order.
1. On Prescription: Garcia’s action, whether treated as an enforcement of the 1932 judgment or an action upon the 1933 written deed of sale, had prescribed. Under Article 1144 of the Civil Code (and Section 43 of Act No. 190), such actions must be brought within ten years. Garcia filed her case in 1956, 23-24 years after the sale and deed. Her claim of adverse possession was unavailing because registered land cannot be acquired by prescription.
2. On Cause of Action / Registration Defects: The complaint failed to allege that the sheriff’s certificate of sale (auction sale) was registered with the Register of Deeds. Registration of the certificate of sale is an essential requirement for its validity under the law (Act No. 190, Sec. 463), as it informs judgment debtors and subsequent lien creditors of their 12-month redemption period. The final deed of sale (issued after redemption) does not require such annotation. The auction sale was never registered, making it too late to do so after 23 years.
3. Supervening Event / Satisfaction of Judgment: A prior Supreme Court decision (Concepcion Ocampo, et al. vs. Maria A. Garcia, G.R. No. L-11260) had already directed the cancellation of the levy annotation on TCT No. 28709 because the rentals (P5,200) Garcia received from the property more than satisfied the original judgment debt of P1,630.80. With the levy cancelled and the sheriff’s sale never annotated, Garcia’s cause of action was extinguished. The land could be considered redeemed by the application of the rentals.