Calacala v. Republic
REITERATIONFacts
The Antecedents: Spouses Camilo and Conchita Calacala, predecessors-in-interest of the petitioners, owned a parcel of land in Rosales, Pangasinan. To secure the provisional release of an accused in a criminal case, they offered this land as a property bond. When the accused failed to appear, the bond was forfeited, and the court ordered the land levied and sold to satisfy the P3,500.00 judgment. A Sheriff's Certificate of Sale was issued to the Republic of the Philippines on September 24, 1982, and registered on October 5, 1982, granting the spouses one year to redeem the property. The spouses Calacala died without redeeming the land. Procedural History: Claiming ownership as heirs, the petitioners filed a complaint for Quieting of Title and Cancellation of Encumbrance against the Republic and Sheriff Juan C. Marquez before the Regional Trial Court (RTC) of Rosales, Pangasinan. The Republic filed a Motion to Dismiss, arguing the complaint failed to state a cause of action and that the right to redeem had prescribed. The RTC granted the motion and dismissed the complaint. The petitioners' motion for reconsideration was denied by the RTC. The Petition: The petitioners are seeking review of the RTC's dismissal and denial of reconsideration via a petition for review on certiorari under Rule 45 of the Rules of Court. They contend that their complaint states a sufficient cause of action, that the case for quieting of title has not prescribed, and that the Republic has not perfected its title. Their primary argument is that the Republic's failure to secure a Certificate of Final Sale, execute an Affidavit of Consolidation of Ownership, and obtain a writ of possession within ten years from the registration of the Certificate of Sale resulted in the prescription, abandonment, or waiver of the Republic's rights, thereby allowing them to retain ownership.
Issue(s)
Whether the complaint for Quieting of Title and Cancellation of Encumbrance stated a sufficient cause of action, and whether the Republic of the Philippines had perfected its title to the land in question. Whether the case for quieting of title had prescribed.
Ruling
The Supreme Court denied the petition and affirmed the resolution and order of the trial court, dismissing the petitioners' complaint.
Ratio Decidendi
On the issue of whether the complaint stated a sufficient cause of action and whether the Republic had perfected its title: The Court held that an action for quieting of title requires the plaintiff to have legal or equitable title to the property and that the alleged cloud on the title must be invalid or inoperative. In this case, the petitioners failed to meet these requisites. Their claim of ownership was based solely on the Republic's alleged failure to take further steps after the registration of the Sheriff's Certificate of Sale, such as securing a Certificate of Final Sale, executing an Affidavit of Consolidation of Ownership, and obtaining a writ of possession. However, the predecessors-in-interest of the petitioners lost their rights to the property upon failure to redeem it within the one-year period. The Republic's inaction did not restore these lost rights. The Court emphasized that prescription does not lie against the government, and the government cannot be bound or estopped by the negligence or mistakes of its officials. Section 33, Rule 39 of the 1997 Rules of Civil Procedure explicitly states that upon the expiration of the right of redemption, the purchaser acquires all the rights, title, interest, and claim of the judgment obligor. The issuance of a final deed of sale is merely a formality confirming the title already vested in the purchaser. Therefore, the petitioners lacked the necessary legal or equitable title to maintain an action for quieting of title. On the issue of prescription: The Court reiterated that the failure of the petitioners' predecessors-in-interest to redeem the property within the one-year period from the registration of the Sheriff's Certificate of Sale rendered the sale absolute. The subsequent failure of the Republic to take further steps, such as securing a final certificate of sale or a writ of possession, did not revive the right of redemption or cause the Republic's ownership to prescribe. The Court pointed out that prescription does not run against the government. Thus, the Republic's right to the property, perfected by the expiration of the redemption period, did not prescribe. The Court also noted that the validity of the Sheriff's Certificate of Sale was not put in issue by the petitioners, further undermining their claim.
Main Doctrine
The failure of the Republic to secure a Certificate of Final Sale, execute an Affidavit of Consolidation of Ownership, and obtain a writ of possession within ten (10) years from the registration of the Sheriff's Certificate of Sale does not operate to restore ownership to the foreclosed party, as prescription does not lie against the government, and the expiration of the redemption period vests ownership in the purchaser.