Primary Holding

The Supreme Court upheld the validity of the auction sales, ruling that the notice requirements under P.D. No. 464 were sufficiently complied with. The Court emphasized that personal service of notice via registered mail satisfies the legal requirements even if the notice was not personally received. Constructive notice through compliance with statutory procedures was deemed adequate.

Background

G.R. No. 137534 (Aquino Case): The Aquino spouses' 612-square meter lot in East Avenue Subdivision, Diliman, Quezon City, was sold in 1984 for non-payment of property taxes from 1975 to 1982. They withheld payment as a protest against the Marcos regime. G.R. No. 138624 (Torrado Case): A 407-square meter property at No. 20 North Road, Cubao, Quezon City, owned by Solomon Torrado, was sold in 1983 due to unpaid property taxes from 1976 to 1982. Notices were sent to an insufficient address, "Butuan City," causing them to be undelivered.

Facts

• 1. The Aquino spouses admitted deliberate non-payment of taxes as a form of protest.
• 2. Notices of tax delinquency were sent via registered mail, but the Aquinos claimed they never received them.
• 3. In Torrado’s case, notices were repeatedly sent to an insufficient address, "Butuan City," despite his actual residence being in Quezon City.
• 4. Both properties were sold at public auctions, and subsequent owners consolidated titles.

Arguments of the Petitioners

• 1. Aquino: Claimed lack of proper notice regarding tax delinquency and auction sale; argued that mailing to an outdated address was insufficient.
• 2. Torrado Heirs: Contended that the City Treasurer was negligent for sending notices to an insufficient address when a more complete address was available in tax records.

Arguments of the Respondents

• 1. Asserted full compliance with notice requirements under P.D. No. 464.
• 2. Argued that sending notices to the last known address on record via registered mail satisfied legal obligations.
• 3. Emphasized that constructive notice suffices under the law.

Issues

• 1. Was there a failure to satisfy notice requirements under P.D. No. 464?
• 2. Is actual notice required, or is constructive notice sufficient?
• 3. Were the auction sales valid despite alleged deficiencies in notice?
• 4. Did the City Treasurer exercise due diligence in serving notices?

Ruling

• 1. Notice Requirements: Sending notices to the taxpayer's address on record is sufficient. Compliance with statutory requirements satisfies due process.
• 2. Constructive vs. Actual Notice: Constructive notice via registered mail satisfies due process even if not personally received, as long as statutory procedures are followed.
• 3. Validity of Auction Sales: Confirmed due to proper procedural compliance. Auction sales were not invalidated by the fact that notices were not received, as the City Treasurer followed legal mandates.
• 4. Due Diligence: The City Treasurer was not negligent as notices were sent to the addresses listed in official tax records.

Doctrines

• 1. Constructive Notice Doctrine: Legal sufficiency of notice sent to the last known address on record, even if the notice is not personally received.
• 2. Statutory Construction Principle: Statutes must be construed as a whole to determine legislative intent, emphasizing that the law does not require personal receipt of notices.
• 3. In Personam Proceedings Principle: Tax sales are in personam proceedings, requiring notice to the taxpayer, but not necessarily actual receipt.

Key Excerpts

• 1. "Notice of delinquency as required in Section sixty-five hereof shall be sufficient for the purpose."
• 2. "The fact that petitioners were not able to read their notices is of no consequence to the annulment of the auction sale."

Precedents Cited

• 1. Talusan v. Tayag: Emphasized that tax sales are in personam proceedings, requiring notice to the taxpayer, but not personal receipt.
• 2. Aisporna v. Court of Appeals: Discussed statutory construction principles, highlighting the importance of interpreting laws in their entirety.

Statutory and Constitutional Provisions

• 1. Presidential Decree No. 464: Real Property Tax Code provisions on notice and sale procedures.
• 2. Local Government Code of 1991: Sections 197 to 283, governing local taxation and property tax collection.