National Housing Authority v. Basa
REITERATIONFacts
The Antecedents: Spouses Augusto and Luz Basa obtained a loan from the National Housing Authority (NHA) secured by a mortgage on their Quezon City properties. The Basa spouses failed to repay the loan despite repeated demands. Consequently, the NHA initiated extrajudicial foreclosure proceedings for the mortgaged properties. Procedural History: Following the foreclosure sale where NHA was the highest bidder, the sheriff's certificate of sale was registered and annotated on the owner's duplicate copies of the titles. The original titles, however, were lost in a fire that gutted the Quezon City Hall. After the redemption period expired without the Basa spouses redeeming the properties, NHA consolidated ownership and sought a writ of possession. The Regional Trial Court (RTC) granted the writ. Subsequently, the Basa spouses and Eduardo Basa intervened, seeking to nullify the foreclosure sale and cancel the writ of possession, arguing procedural defects and that the redemption period had not yet expired due to improper registration. The RTC admitted the intervention and issued a preliminary injunction, which NHA challenged. The Court of Appeals initially ruled in favor of NHA, nullifying the RTC's orders admitting the intervention and granting the injunction, but later reconsidered and set aside its decision, allowing the intervention and finding that the redemption period had not expired. The Petition: The National Housing Authority filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to overturn the Court of Appeals' Amended Decision. NHA argues that the annotation of the sheriff's certificate of sale on the owner's duplicate titles, despite the original titles being burned, constitutes sufficient registration. NHA contends that the redemption period had expired and that the writ of possession should have been issued as a matter of course. NHA also disputes the Court of Appeals' reliance on prior jurisprudence regarding registration and asserts that the RTC's initial order granting the writ of possession had become final and executory.
Issue(s)
Whether the annotation of the sheriff's certificate of sale on the owner's duplicate title, in lieu of the burned original titles, constitutes sufficient compliance with the requirement of registration for the commencement of the redemption period. Whether the Court of Appeals erred in finding that the lower court did not act with grave abuse of discretion amounting to lack of jurisdiction in admitting the respondents' intervention and granting the equitable writ of injunction. Whether the petition complies with the requirements of Rule 45 of the Rules of Court.
Ruling
The Supreme Court granted the petition, set aside the Amended Decision of the Court of Appeals, and reinstated the writ of possession in favor of NHA. The Court ruled that the annotation of the sheriff's certificate of sale on the owner's duplicate title was sufficient registration, and thus the redemption period had expired, barring respondents' right to redeem.
Ratio Decidendi
On the sufficiency of registration: The Court held that the prevailing rule is that effective registration occurs once the registrant has fulfilled all requirements for entry and annotation, with the remaining task solely incumbent on the Register of Deeds. Citing jurisprudence, particularly Development Bank of the Philippines v. Acting Register of Deeds of Nueva Ecija and Autocorp Group v. Court of Appeals, the Court clarified that entry in the primary book is equivalent to registration, even if annotation on the original titles is impossible due to their destruction. NHA complied with all procedural requirements for registration by presenting the sheriff's certificate of sale to the Register of Deeds, which was entered and annotated on the owner's duplicate title. The destruction of the original titles was not attributable to NHA, and the subsequent Affidavit of Consolidation of Ownership was executed after the redemption period, which commenced from the date of registration of the certificate of sale. Therefore, respondents lost their opportunity to redeem the properties. On the admission of intervention and injunction: The Court found that the Court of Appeals erred in allowing the intervention and issuing the injunction. A writ of possession, after the consolidation of title in the buyer's name due to the mortgagor's failure to redeem, becomes a matter of right and its issuance is a ministerial function. The RTC's initial order granting the writ of possession had attained finality. The respondents' attempt to question the foreclosure sale through intervention after the redemption period had expired and consolidation of title had occurred was deemed an improper attempt to circumvent the established procedure and the finality of the earlier order. The issuance of an injunction would have rendered the writ of possession ineffectual, contrary to established jurisprudence that disallows injunctions to prohibit the issuance of a writ of possession. On compliance with Rule 45: The Court found that NHA substantially complied with the requirements of Section 4, Rule 45 of the Rules of Court by attaching material portions of the record, including the decisions of the Court of Appeals and relevant titles. The Court reiterated the principle that cases should be decided on their merits rather than on technicalities, and that procedural rules should be liberally construed to promote substantial justice. Furthermore, the verification of the petition was found to conform to the requirements of Section 4, Rule 7 of the Rules of Court, as the affiant declared that the allegations were true and correct to the best of his personal knowledge.
Main Doctrine
The entry of a sheriff's certificate of sale in the primary entry book of the Register of Deeds, even if annotation on the original titles is impossible due to their destruction, constitutes sufficient registration for purposes of commencing the redemption period, provided the registrant has complied with all requirements for entry and annotation.