G.R. No. L-18603; February 28, 1963
CANDIDA PIANO, petitioner, vs. GENEROSA CAYANONG, REGALADO BELLONES and FRANCISCO PILAPIL, respondents.

FACTS

Petitioner Candida Piano executed a mortgage over a parcel of land in favor of respondents Generosa Cayanong and Regalado Bellones. Upon her default, a foreclosure suit was filed. The parties submitted a compromise agreement wherein Piano admitted the debt and agreed to pay P2,000.00 within 30 days from a judgment based on the compromise, with the stipulation that failure to pay would authorize the court to sell the mortgaged property. The trial court rendered a judgment based on this compromise, ordering Piano to pay P2,400.00 within 90 days, and upon her failure, the property was to be sold at public auction. Piano failed to pay. The property was sold at a judicial auction to Cayanong and Bellones as the only bidders. The sheriff’s certificate of sale erroneously included a one-year redemption period. The sale was later confirmed by the court, and a writ of possession was issued. Subsequently, Piano deposited redemption money with the court. However, a junior encumbrancer, Francisco Pilapil, had already redeemed the property from Cayanong and Bellones a day after Piano’s deposit.

ISSUE

The primary issue is whether Piano retained a right of redemption after the confirmation of the judicial sale in a mortgage foreclosure proceeding based on a compromise judgment.

RULING

The Supreme Court ruled that Piano had no right of redemption. The Court explained that a judicial foreclosure of a mortgage under Section 2 of Rule 70 (now Section 6, Rule 68) of the Rules of Court does not grant a statutory right of redemption to the mortgagor after the confirmation of the sale. The judgment, being based on a valid compromise agreement, had the effect of res judicata and was a final adjudication. The Court rejected Piano’s argument that the compromise judgment was invalid for not stating findings of fact and law, holding that a court need not make such findings when rendering judgment based on a compromise, as the agreement itself binds the parties. Furthermore, the erroneous insertion of a one-year redemption period in the sheriff’s certificate of sale did not create a right where none existed by law. The confirmation of the sale vested title in the purchasers, Cayanong and Bellones, extinguishing any possible equity of redemption. Consequently, the subsequent redemption by the junior encumbrancer, Pilapil, was valid, and Piano’s attempt to redeem was properly denied. The Court distinguished the cited cases on extension of redemption periods as inapplicable, as they involved legal or physical impossibilities that did not exist here. The decision of the Court of Appeals was affirmed.