Go v. Ko
REITERATIONFacts
The Antecedents: Petitioner Davidson Go (Go) filed a Petition for consolidation of title over Lot No. 23-H-1, cancellation of Transfer Certificate of Title (TCT) No. 59729, and issuance of a new title in his name. Go claimed ownership based on a tax delinquency auction sale conducted by the City Government of Quezon City on April 7, 2011, and a subsequent Final Bill of Sale, alleging failure of the registered owner to redeem the property within one year. Procedural History: Respondents Spouses Henry and Janet Ko (Spouses Ko) opposed Go's petition, asserting their ownership of the property based on a Deed of Absolute Sale from Lexus Development, Inc. and continuous possession since 1996. They claimed to have learned of the auction sale on March 13, 2012, and paid the redemption price on March 29, 2012, within the one-year redemption period. The Regional Trial Court (RTC) ruled in favor of Go, finding no valid redemption due to the lack of proof of authority from Spouses Ko to redeem for the registered owner. The Court of Appeals (CA) reversed the RTC, holding that the Deed of Absolute Sale was valid and that Spouses Ko's possession vested them with sufficient legal interest to effect a valid redemption. The CA directed the City Treasurer's Office to accept the redemption payment and issue a certificate of redemption. The Petition: Go assails the CA's Decision and Resolution, arguing that Spouses Ko's failure to submit proof of ownership, legal interest, or authority to redeem to the City Treasurer's Office within the redemption period constituted a failure of redemption, justifying the issuance of the Final Bill of Sale in his favor. Spouses Ko countered that RA 7160 does not require such proof from a party paying for the delinquent owner, and their payment was credited to the delinquent owner, Lexus.
Issue(s)
Whether Spouses Ko validly redeemed the subject property despite not being the registered owners thereof and without presenting proof of ownership or legal interest to the City Treasurer's Office at the time of payment. Whether the undated and unnotarized Deed of Absolute Sale between Janet Ko and Lexus Development, Inc. is valid and binding.
Ruling
The Petition is denied. The Decision dated August 14, 2019, and the Resolution dated June 17, 2020, of the Court of Appeals in CA-G.R. CV No. 111924 are affirmed.
Ratio Decidendi
On the validity of the redemption: The Court affirmed the CA's ruling that Spouses Ko validly redeemed the subject property. Section 261 of RA 7160 grants the owner or person with legal interest, or their representative, the right to redeem property sold at a public auction within one year from the date of sale. Spouses Ko established their legal interest through a valid Deed of Absolute Sale with the registered owner, Lexus Development, Inc., and through their open, continuous, exclusive, and notorious possession of the property since 1996. The payment of the redemption price was made within the one-year period, as evidenced by an official receipt, and was credited to Lexus, the delinquent registered owner. The Court reiterated the policy of the law to aid redemption and to give a liberal construction to redemption laws where no injury will follow. On the validity of the Deed of Absolute Sale: The Court upheld the CA's finding that the Deed of Absolute Sale between Janet Ko and Lexus Development, Inc. is valid and binding, despite being undated and unnotarized. While Article 1358 of the Civil Code requires the sale of real property to be in a public document, this requirement pertains to efficacy and enforceability against third persons, not to the validity of the contract between the parties. The authenticity and due execution of the deed were not disproven during the trial, thus establishing a valid conveyance of real rights from Lexus to Janet, conferring upon Spouses Ko the legal interest necessary to redeem the property.
Main Doctrine
Spouses Ko validly redeemed the subject property despite not being the registered owners and not submitting proof of ownership or legal interest at the time of payment, as their established legal interest through a valid Deed of Absolute Sale and open possession, coupled with the timely payment of the redemption price credited to the delinquent registered owner, satisfied the requirements of law and jurisprudence favoring redemption.