Republic of the Philippines v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Pantranco North Express, Inc. (PNEI) obtained a loan from National Investment and Development Corporation (NIDC), secured by a mortgage on its properties, including the Pantranco bus terminal in Tarlac, Tarlac, covered by TCT No. 101055. NIDC transferred its rights to Philippine National Bank (PNB), which subsequently transferred these rights to the Asset Privatization Trust (APT) pursuant to Presidential Proclamation No. 50. Due to labor disputes and the failure of promised capital infusion, PNEI ceased operations. Labor unions instituted cases, leading to the execution sale of PNEI's assets, including the Tarlac property, to satisfy judgment debts. Respondent Domingo P. Uy was the highest bidder at P4,868,100.00 in the auction sale on September 23, 1994. A certificate of sale was issued and registered on October 24, 1994. Procedural History: On October 23, 1995, APT tendered P5,454,272.00 to redeem the property, representing the bid price plus accrued interests and deposit fee, but excluding taxes and other expenses. The sheriffs did not issue a certificate of redemption. The following day, October 24, 1995, the sheriffs executed a Final Deed of Sale in favor of Domingo P. Uy, which was submitted for registration. The Register of Deeds held registration in abeyance due to APT's claim of redemption. Labor Arbiter Pablo C. Espiritu, Jr. declared APT's redemption void and ineffectual in an Order dated February 23, 1996, confirming the Sheriff's Final Deed of Sale and ordering the cancellation of TCT No. 101055 and issuance of a new title to Uy. The National Labor Relations Commission (NLRC) dismissed APT's appeal on October 16, 1996. The Petition: The Republic of the Philippines, represented by APT, filed a special civil action for certiorari seeking to nullify the Order of the Labor Arbiter and the Decision of the NLRC, raising the issue of whether the redemption period under Section 30, Rule 39 of the 1964 Revised Rules of Court is twelve (12) months or one year from the date of registration of the sale.
Issue(s)
Whether the redemption period of twelve (12) months under Section 30, Rule 39 of the 1964 Revised Rules of Court is twelve (12) months or one year from the date of registration of the sale. Whether APT's redemption of the subject property was valid and effectual.
Ruling
The petition is dismissed. The order dated February 23, 1996, of Labor Arbiter Pablo C. Espiritu, Jr., and the decision dated October 16, 1996, of the National Labor Relations Commission are affirmed.
Ratio Decidendi
On the redemption period: The Court reiterated that the phrase "after the sale" in the context of redemption periods means "after the date of registration of the certificate of sale." The core issue was the computation of "twelve (12) months." Applying Article 13 of the Civil Code, the Court held that twelve (12) months, as provided in Section 30, Rule 39 of the 1964 Revised Rules of Court, consists of three hundred sixty (360) days, not three hundred sixty-five (365) days. This interpretation is crucial because the redemption period under the old rule was explicitly stated as "twelve (12) months," which, under the rules of computation in the Civil Code, is not necessarily equivalent to one year. The Court noted that the 1997 Rules on Civil Procedure, effective July 1, 1997, amended this to "one (1) year from the date of the registration of the certificate of sale." However, the case at bar was governed by the 1964 Rules. On the validity of APT's redemption: Based on the established redemption period of twelve (12) months or 360 days from the registration of the certificate of sale on October 24, 1994, APT's tender of redemption on October 23, 1995, fell outside this period. The registration of the certificate of sale occurred on October 24, 1994. Therefore, the twelve-month period expired on October 23, 1995. While APT tendered the amount on October 23, 1995, the Court's computation based on Article 13 of the Civil Code (360 days for 12 months) meant that the redemption period technically ended on October 23, 1995. The fact that APT did not include taxes and other expenses in its tender, and that the sheriffs did not issue a certificate of redemption, further weakened its claim. The subsequent execution of the Sheriff's Final Deed of Sale in favor of Domingo P. Uy on October 24, 1995, and its submission for registration, solidified Uy's claim over the property.
Main Doctrine
The redemption period of twelve (12) months under Section 30, Rule 39 of the 1964 Revised Rules of Court is computed as 360 days, not 365 days, applying Article 13 of the Civil Code.