Reyes v. De Los Santos
REITERATIONFacts
The Antecedents: Defendant spouses Oscar de los Santos and Aurora T. Ingalla obtained a loan from the Rehabilitation Finance Corporation (RFC), secured by a real estate mortgage. Upon failure to pay, the RFC foreclosed the mortgage extrajudicially. The property was sold at public auction to plaintiff Arsenio Reyes, who was the highest bidder. The Certificate of Sale fixed the redemption period. Plaintiff Reyes executed an Affidavit of Consolidation of Ownership and obtained a new Transfer Certificate of Title in his name. Procedural History: Plaintiff Reyes filed an ejectment case against the defendant spouses, alleging he had consolidated ownership of the property after their failure to redeem. The defendants, in their answer, asserted that they had validly redeemed the property by paying the principal and interest to the Provincial Sheriff of Rizal. The lower court ruled in favor of the defendants, declaring the cancellation of the original title and the issuance of a new title in the plaintiff's name void, and ordering the Register of Deeds to issue a new title in favor of the defendants, with a reimbursement for realty taxes paid by the plaintiff. The Petition: Plaintiff Arsenio Reyes appealed the decision of the lower court, raising objections to the validity of the redemption based on alleged payment to the wrong person (the provincial sheriff) and failure to pay the full redemption price.
Issue(s)
Whether the Provincial Sheriff of Rizal was authorized to accept the redemption money. Whether the redemption was invalid due to alleged failure to pay the full redemption price, including trifling amounts for assessments and documentary stamps.
Ruling
The Supreme Court affirmed the decision of the lower court, upholding the validity of the redemption made by the defendants. The Court dismissed the plaintiff's appeal, finding no merit in his objections regarding the authority of the Provincial Sheriff to accept redemption money and the alleged insufficiency of the redemption payment. The Court ordered treble costs against the appellant.
Ratio Decidendi
On the authority of the Provincial Sheriff to accept redemption money: The Court reiterated its ruling in Reyes v. Chavoso and Reyes-Gregorio v. Reyes that the Provincial Sheriff is a proper party to accept redemption money. Citing Section 31 of Rule 39 of the Rules of Court, the Court stated that payments for redemption may be made to the officer who made the sale. This principle was supported by previous jurisprudence dating back to 1915, establishing that payment to the Provincial Sheriff to effect redemption was valid even prior to the current Rules of Court. Therefore, the plaintiff's contention that the redemption was invalid because payment was made to the sheriff was without legal basis. On the alleged insufficiency of the redemption price: The Court found the plaintiff's argument regarding trifling amounts allegedly not included in the redemption payment to be without merit, characterizing such objections as "picayune." The Court referred to its ruling in Reyes v. Chavoso, which addressed a similar contention. The Court emphasized that under the last paragraph of Section 30, Rule 39 of the Rules of Court, if a purchaser pays assessments or taxes, they must give notice to the officer who made the sale and file it with the registrar of deeds. Without such notice, the property may be redeemed without paying those assessments, taxes, or liens. Since the plaintiff failed to allege or prove that he provided such notice to the sheriff regarding additional payments for assessments and documentary stamps, he could not fault the sheriff for accepting only the purchase price and interest. The Court noted that the lower court itself ordered the defendants to reimburse the plaintiff for realty taxes, indicating a practical resolution of the reimbursement issue.
Main Doctrine
The Provincial Sheriff is a proper party to accept redemption money in accordance with law, and the redemption price must include all sums due, including assessments and taxes, provided proper notice is given by the purchaser.