Jose F. Puzon vs. Alejandra Abellera (substituted by Tomasa D. Domondon), G.R. No. 04690
### Facts:
1. **Subject Property**: Alejandra Abellera owned a two-hectare lot known as Lot 1-B subdivision plan (LRC) PSU-33174, covered by TCT No. 8103.
2. **Background Ruling**:
– Issued under RA 931, titles within Baguio Townsite Reservation were invalidated by Supreme Court cases (29 SCRA 517, 52 SCRA 238).
– PD 1271 later partially validated pre-1973 titles with compliance conditions.
3. **Auction Sale**:
– On October 10, 1977, the property was auctioned due to unpaid real property taxes for 1971-1977.
– Jose F. Puzon, the lone bidder, won the bid for P3,253.95.
4. **Procedural Steps**:
– Puzon received a certificate of sale a year post-auction, but registration required court confirmation.
– Puzon filed a court case to consolidate ownership.
– Tomasa D. Domondon, Abellera’s successor, opposed consolidating ownership asserting improper tax assessment and auction sale. She deposited P4,780.00 with court exceeding Puzon’s bid.
5. **Lower Court Ruling**:
– The CFI and later the IAC declared the auction sale null and void due to improper tax assessment and insufficient notice.
### Issues:
1. Whether the property was tax-delinquent for 1971-1977.
2. Whether the auction sale was valid and legally executed.
### Court’s Decision:
1. **Tax Delinquency**:
– **Curtative Nature of PD 1271**:
– Recognizes pre-1973 title validity upon compliance with specified conditions.
– Good faith improvements respected.
– **Court Analysis**:
– The property remained part of the public domain until valid title compliance.
– Retroactive title validation would subject the property to tax only if conditions met retrospectively.
– **Conclusion**:
– Abellera was not tax liable for 1971-1977 as the land was technically public domain.
2. **Auction Sale Validity**:
– **Notification Requirement**:
– Law mandates actual notice to the property owner as a precondition.
– **Court Findings**:
– Lack of proper notice vitiated the due process rights.
– Affirmed by precedents like Cabrera v. Prov. Treasurer and Vivencio v. Quintos.
– **Conclusion**:
– The auction sale was null since Abellera wasn’t properly notified.
### Doctrine:
– **Retrospective Title Validation**:
– Titles are retroactively valid from the date of issuance upon compliance with PD 1271.
– Tax liabilities accrue only after compliance completion.
– **Due Process in Tax Sales**:
– Valid tax sale necessitates actual notice to affected landowners; failure invalidates the sale.
### Class Notes:
– **PD 1271 (1977)**:
– Nullifies illicit titles within the Baguio Townsite Reservation.
– Validates such titles on conditions met.
– **Real Property Tax Code (PD 464)**:
– Sections on notification (59, 65, 73, 76) necessitate actual notice to delinquent owners for tax sales.
– Article 4 NCC prohibits retroactive law unless clearly expressed.
– **Key Principles**:
– Good faith reliance on torrens title before 1973.
– Substantive due process in administrative property proceedings.
– The Baguio Townsite reservation’s special judicial history.
### Historical Background:
– **Baguio Townsite Reservation**:
– Established under Civil Reservation Case No. 1, GLRO Record No. 211.
– Cadastral Act No. 2259 complexities led to conflicting land claims.
– **Legal Transformations**:
– RA 931 allowed late title claims within 40 years of public land declarations.
– SC nullified Baguio townsite titles under RA 931, later addressed by PD 1271.
– PD 1271’s enactment was a partial accommodation to good-faith landowners operating under flawed legal assumptions.
This case exemplifies the intersection of administrative property proceedings with constitutional property rights within the context of Philippines land title legislation.
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