Valbueco v. Province of Bataan
REITERATIONFacts
The Antecedents: Petitioner Valbueco, Inc. was the registered owner of eight parcels of land in Bataan. Due to unpaid real property taxes totaling P70,762.90, these properties were sold at public auction, with the Province of Bataan emerging as the winning bidder. Years later, Valbueco, Inc. filed a complaint to nullify the tax sale and the subsequent consolidation of title and ownership in favor of the Province, alleging procedural irregularities in the distraint, levy, and auction sale, including lack of proper notice and publication. Procedural History: The Regional Trial Court (RTC), Branch 1, Balanga City, Bataan, dismissed Valbueco, Inc.'s civil complaint. The petitioner subsequently amended its complaint to include the Secretary of the Department of Agrarian Reform and individual beneficiaries, alleging that the properties were unlawfully included in the Comprehensive Agrarian Reform Program (CARP). The DAR Secretary and the CARP beneficiaries moved to dismiss, arguing lack of jurisdiction and failure to exhaust administrative remedies. The RTC initially dismissed the amended complaint but later reconsidered, asserting jurisdiction over the validity of the auction sale and consolidation of ownership. After trial, the RTC dismissed the complaint on the merits. The Court of Appeals (CA) affirmed the RTC's decision, deleting only the award of attorney's fees. Valbueco, Inc. then filed the present petition for review on certiorari. The Petition: This case is before the Supreme Court via a Petition for Review on Certiorari under Rule 45 of the Rules of Civil Procedure, assailing the decision of the Court of Appeals. The petitioner argues that the tax sale and subsequent consolidation of title were invalid due to alleged procedural defects in the distraint, levy, and auction sale, specifically the lack of proper notice and publication. The Supreme Court, however, found that the issues raised primarily involve questions of fact, which are beyond the scope of a Rule 45 petition. Furthermore, the Court found that the petitioner failed to present preponderant evidence to support its claims of irregularities, and that the evidence presented by the respondents, despite the absence of documentary proof due to lost records, was sufficient to uphold the validity of the tax sale.
Issue(s)
Whether the Supreme Court can pass upon questions of fact in a petition for review on certiorari. Whether the tax sale and subsequent consolidation of title were attended by irregularities that would invalidate them; and whether petitioner Valbueco, Inc. presented sufficient evidence to prove its allegations of irregularities in the tax sale. Whether the Province of Bataan complied with the procedural requirements of Presidential Decree No. 464 (Real Property Tax Code) in conducting the tax sale, considering the presumption of regularity and burden of proof.
Ruling
The petition is denied. The assailed decision of the Court of Appeals, which affirmed the Regional Trial Court's dismissal of the case, is affirmed. The Supreme Court held that the issues raised involve questions of fact, which are beyond the scope of a petition for review on certiorari under Rule 45. Furthermore, the Court found that petitioner failed to present preponderant evidence to prove the alleged irregularities in the tax sale. The Court also noted that the Province of Bataan complied with the provisions of PD 464 regarding the sending of notices, and any fault lay with the petitioner for failing to update its address.
Ratio Decidendi
On the issue of questions of fact: The Court reiterated that in a petition for review on certiorari under Rule 45, it can only pass upon questions of law and is not a trier of facts. The issues raised by the petitioner, particularly concerning the alleged lack of notice and publication in the tax sale, are undeniably factual in nature. Therefore, on this ground alone, the petition should be dismissed. The Court emphasized that it does not inquire into and review the evidence presented by the parties, which was already passed upon by the lower courts. On the alleged irregularities in the tax sale and sufficiency of evidence: The Court found that petitioner Valbueco, Inc. utterly failed to present preponderant evidence to support its allegations that the auction sale of the subject properties due to tax delinquency was attended by irregularities. The two witnesses presented by the petitioner were neither competent nor convincing to attest with reasonable certainty that the respondents failed to observe the procedural requirements of PD 464. The Court found the factual findings of the trial court, as affirmed by the CA, to be satisfactory and saw no reason to disturb them. The Court reiterated the general rule in civil cases that the party with the burden of proof must establish its case by a preponderance of evidence. Petitioner failed to establish its cause of action by convincing evidence. The Court stressed that plaintiffs in civil cases must rely on the strength of their own evidence and not on the weakness of the defendant's claim. Even if the plaintiff's evidence may be stronger than the defendant's, it is insufficient if it does not establish the cause of action. The "equiponderance of evidence" rule dictates that when the scales are in equipoise, the court will find for the defendant. On compliance with PD 464, presumption of regularity, and burden of proof: The Court examined the testimony of petitioner's witnesses, Gaudencio P. Juan and Atty. Domingo Lalaquit, and found their claims regarding the lack of notice and publication to be based on hearsay, assumptions, speculation, and inconsistencies. Juan admitted he was not the custodian of records and had not seen any notice, leading to his assumption. Atty. Lalaquit only handled the matter after the sale. The Court noted that petitioner changed its office address without informing the respondent Province, and PD 464, Section 73, allows the treasurer to send notices to the address shown in the tax rolls or the taxpayer's residence if known, giving the treasurer an option. The Court deduced that the notices were likely sent to the address indicated in the TCTs and tax declarations, and the fault lay with petitioner for not updating its address. While acknowledging that there can be no presumption of regularity in administrative actions that deprive a taxpayer of property, the Court distinguished the present case from those where such presumption was not applied. In this case, the respondent Province, through its witness, unequivocally attested that the procedural requisites mandated by PD 464 were observed. Although documentary proof was missing due to the passage of time and loss of files, the witness testified under oath with personal knowledge. The Court found it understandable that minute details could not be recalled after a long period.
Main Doctrine
Failure to present preponderant evidence to prove irregularities in a tax sale, coupled with the presumption of regularity in the performance of official duties, leads to the dismissal of the complaint to nullify the sale and reconvey the property.