G.R. No. L-58281 November 13, 1991
DIONISIO GOMEZ, ET AL., plaintiffs-appellees, vs. MARCELO GEALONE, ET AL., defendants-appellants.

FACTS

Plaintiffs-appellees secured a favorable judgment against defendants-appellants, including an award of actual damages. To satisfy the monetary award, the Provincial Sheriff levied upon and sold at public auction two properties of defendants Zoilo Esber and Lucia G. de Esber: a 12-hectare agricultural lot and a residential lot with a house. Plaintiffs-appellees were the highest bidders. The certificate of sale was issued, and after the one-year redemption period lapsed without redemption, a final bill of sale and a writ of possession were issued. Possession was delivered to the plaintiffs-appellees.
Six months after the redemption period expired, defendants-appellants filed a motion to set aside the execution sale. They argued that the levied properties were exempt from execution, claiming the residential property was a family home or homestead. They also contended the sale price was grossly inadequate compared to the properties’ value, resulting in an iniquitous transaction that deprived them of property without due process.

ISSUE

May a sheriff’s sale on execution be set aside after the expiration of the redemption period on the grounds that the properties are exempt from execution or that the price was grossly inadequate?

RULING

No. The Supreme Court affirmed the trial court’s denial of the motion to set aside the sale. On the first ground, claims for exemption from execution under the Rules of Court must be asserted before the sale is conducted, not after the redemption period has expired. The purpose of this rule is to prevent judgment creditors from being deprived of the fruits of their verdict through belated claims. By failing to present their claim for exemption prior to the auction, defendants-appellants waived their right to assert it.
On the second ground, the Court found the sale price was not grossly inadequate. The combined assessed value of the properties was approximately P3,050 to P3,790. They were sold for P3,522.50. Even assuming the market value was higher, the price did not shock the conscience. Gross inadequacy of price alone is not a ground to nullify an execution sale, especially when the law provides a right of redemption, as the lower price theoretically makes redemption easier for the debtor. The defendants-appellants did not redeem the properties within the statutory period. Therefore, the sale was valid and could not be set aside.