Caballero vs. Laverne Realty & Development Corporation

A tax delinquency sale under the Local Government Code is an in personam proceeding; actual notice of the warrant of levy must be given to the delinquent owner or person having legal interest, or, if they cannot be located, to the administrator or occupant of the property, and noncompliance renders the sale void. A prior purchaser under an unnotarized and unregistered deed of sale has legal interest to assail the sale under Section 267, and the Section 267 deposit applies where there is no dispute that the property is tax delinquent and the interest amount is not oppressive.

Razote was the registered owner of a parcel of land in Las Piñas City covered by TCT No. T-102490. Caballero claims to have purchased the property from Razote in 2008 under an unnotarized Deed of Absolute Sale, which she did not register with the Registry of Deeds. Laverne Realty & Development Corporation is the respondent that acquired the property at the tax delinquency sale whose validity is challenged. The dispute is governed by the Local Government Code of 1991, which prescribes the procedure for real property tax delinquency sales, including notice of delinquency, levy, advertisement, auction, redemption, and the deposit required to assail the validity of a tax sale.

Razote was the registered owner of a parcel of land in Las Piñas City covered by Transfer Certificate of Title No. T-102490. Caballero claimed that she had purchased the property from Razote in 2008 for ₱4,118,100.00, as evidenced by an unnotarized Deed of Absolute Sale, which she failed to register with the Registry of Deeds.

In December 2011, the City Treasurer of Las Piñas City sent Razote, through registered mail, a Final Demand Letter to pay her real property tax delinquencies on the property from 2009 to 2011 in the total amount of ₱12,047.78, inclusive of interest. On January 7, 2012, the City Treasurer issued a Notice of Levy on the property, which was later annotated on TCT No. T-102490. On February 27, 2012, the City Treasurer held a tax delinquency sale where Laverne was declared the winning bidder for the total amount of ₱16,197.41. The City Treasurer subsequently issued to Laverne the corresponding Certificate of Sale, which was also annotated on TCT No. T-102490. Thereafter, the City Treasurer sent Razote, through registered mail, several letters dated November 5, 2012, December 6, 2012, and January 2, 2013, reminding her that her right to redeem the property would expire on February 27, 2013. On March 7, 2013, the City Treasurer issued Razote a Notice of Deed of Conveyance, informing her that her right to redeem had already expired and that the property would be conveyed in favor of Laverne. Thus, on January 16, 2014, the City Treasurer executed a Deed of Conveyance over the property in favor of Laverne.

On September 30, 2014, Caballero filed with the RTC of Las Piñas City a Complaint for nullification of the real property tax delinquency sale against Laverne, Razote, the City Treasurer, and the Registrar of Deeds of Las Piñas City. Caballero argued that the tax delinquency sale was invalid because she was deprived of her right to participate in the delinquency sale: the Notice of Levy was not received by either Razote or her, and the City Treasurer's Notice of Deed of Conveyance and letter reminders regarding the redemption period were served only on the property developer. Caballero also claimed that Laverne unjustly enriched itself because it paid only ₱16,197.41 for property whose fair market value was ₱4,000,000.00. While the case was pending, Caballero caused the annotation of a notice of lis pendens on TCT No. T-102490 and deposited ₱26,239.80 to the RTC as required by Section 267 of the Local Government Code of 1991.

The City Treasurer argued that the sale between Razote and Caballero was not binding on it because it had no knowledge of the same and it was not notarized and registered. The City Treasurer also argued that Caballero failed to exercise her right of redemption, denied Razote's supposed non-receipt of the notices and letters, and pointed out that it even served the same on the property developer, as the property was a vacant lot within the developer's control. For its part, Laverne invoked the presumption of regularity in the City Treasurer's performance of its functions and argued that the tax declarant of record was duly notified of the delinquency, the impending public auction sale, and the redemption period, but still failed to take the legal steps to free herself from tax liabilities. Laverne further argued that since neither the property owner nor any interested party redeemed the property within one year from the sale, the tax delinquency sale in its favor became final, and that Caballero could not expect the City Treasurer to provide her with notices because she admitted that she neither transferred the title in her own name nor annotated the Deed of Absolute Sale on TCT No. T-102490.

Attempts to personally serve summons on Razote failed because she moved out without leaving any forwarding address. Despite service of summons by publication, she still failed to appear, and she was declared in default. Eventually, Caballero was allowed to present evidence ex parte in view of Laverne's failure to appear during the Judicial Dispute Resolution. In 2016, the RTC dismissed the Complaint for failure of Caballero to prove her entitlement to her claims. The RTC ruled that the City Treasurer could not be expected to notify Caballero of the tax delinquency proceedings because she neither registered the sale nor notified the City Treasurer of her purchase. It also found Caballero negligent for failing to pay the real property taxes from the time she bought the property in 2008 until its auction in 2012, and for failing to register the Deed of Absolute Sale with the Register of Deeds. The CA affirmed the RTC Decision, holding that Caballero failed to establish any invalidity or irregularity in the tax delinquency sale. Under Section 258 of the Local Government Code, the warrant of levy must be mailed to or served upon the delinquent owner or person having legal interest therein, or in case they are out of the country or cannot be located, to the administrator or occupant of the property. The CA found that the City Treasurer duly complied by sending its letters and notices to Razote's last known address by registered mail, and rejected Caballero's claim of being entitled to the same notice under Section 258 because she never registered the Deed of Absolute Sale or informed the City Treasurer of the sale. The Supreme Court later noted that the Officer-in-Charge of the Real Property Tax Division of the Treasurer's Office of Las Piñas City testified that even the Final Demand Letter, Reminder Letters, and Clarification Letter sent by the City Treasurer to Razote through registered mail were not received by anyone. Summons could not even be served on Razote because she supposedly moved out of her residential address in Makati years ago. There was also no showing that actual notice of the Warrant of Levy was received by any occupant or administrator of the property. The November 5, 2012 and January 2, 2013 Reminder Letters of the City Treasurer were received by Brittany Corporation, the developer of the property, but there was no showing that Brittany Corporation was the occupant or administrator of the subject property. Laverne also waived its right to present evidence in view of its repeated, unjustified failure to attend the Judicial Dispute Resolution proceedings.

• Standing as Prior Purchaser: Caballero claimed that she had purchased the property from Razote in 2008 and therefore had legal interest in the property; she argued that the tax delinquency sale was invalid and impaired her property rights, giving her standing to sue for nullification.
• Lack of Actual Notice / Section 258 Noncompliance: Caballero argued that the tax delinquency sale was invalid because she was deprived of her right to participate in the delinquency sale; the Notice of Levy was not received by either Razote or her, and the City Treasurer's Notice of Deed of Conveyance and redemption reminders were served only on the property developer.
• Unjust Enrichment: Caballero claimed that Laverne unjustly enriched itself because it paid only ₱16,197.41 for property whose fair market value was ₱4,000,000.00.
• Section 258 Compliance: Caballero faulted the CA for holding that Section 258 was complied with even though Razote did not actually receive the Warrant of Levy sent to her by registered mail.

• Non-binding Sale / Lack of Knowledge: The City Treasurer argued that the sale between Razote and Caballero was not binding on it because it had no knowledge of the same and it was not notarized and registered.
• Failure to Redeem: The City Treasurer argued that Caballero failed to exercise her right of redemption.
• Denial of Non-Receipt / Service on Developer: The City Treasurer denied Razote's supposed non-receipt of the notices and letters, and pointed out that it even served the same on the property developer, as the property was a vacant lot within the developer's control.
• Presumption of Regularity / Notices to Tax Declarant: Laverne invoked the presumption of regularity in the City Treasurer's performance of its functions and argued that the tax declarant of record was duly notified of the delinquency, the impending public auction sale, and the redemption period, but still failed to take the legal steps to free herself from tax liabilities.
• Finality of Sale / No Entitlement to Notice: Laverne argued that since neither the property owner nor any interested party redeemed the property within one year from the sale, the tax delinquency sale in its favor became final; Caballero could not expect the City Treasurer to provide her with notices because she admitted that she neither transferred the title in her own name nor annotated the Deed of Absolute Sale on TCT No. T-102490.

• Standing to Assail the Tax Delinquency Sale: Whether Caballero, as a prior purchaser under an unnotarized and unregistered Deed of Absolute Sale, is a real party-in-interest with legal interest to question the validity of the tax delinquency sale under Section 267 of the Local Government Code.
• Validity of the Tax Delinquency Sale: Whether the CA correctly affirmed the dismissal of Caballero's Complaint despite the alleged non-compliance with Section 258 and other requirements of the Local Government Code, particularly the lack of actual notice of the Warrant of Levy to the delinquent owner or occupant or administrator.
• Applicability of Section 267 and Disposition of Deposit: Whether Section 267 of the Local Government Code applies to Caballero's action and whether the ₱26,239.80 deposit should be released to Laverne as purchaser after the sale is declared void.
• Issuance of a New TCT to Caballero: Whether Caballero is entitled to the issuance of a new Transfer Certificate of Title in her name based on the unnotarized Deed of Absolute Sale.

• Standing to Assail the Tax Delinquency Sale: Yes. Section 267 permits a person having legal interest, even a non-owner, to assail a tax sale if substantive rights are impaired; a prior purchaser's property rights are impaired by an invalid sale.
• Validity of the Tax Delinquency Sale: No. Tax delinquency sales under the Local Government Code are in personam; actual notice of the Warrant of Levy to the delinquent owner or person having legal interest, or the occupant or administrator, is mandatory, and noncompliance voids the sale. The sale was void; Laverne failed to prove compliance.
• Applicability of Section 267 and Disposition of Deposit: Yes. Section 267 applies because there is no dispute that the property was tax delinquent and the interest amount is not oppressive; the deposit of ₱26,239.80 should be released to Laverne.
• Issuance of a New TCT to Caballero: No. The unnotarized Deed of Absolute Sale is not registrable under Section 112 of Presidential Decree No. 1529; Caballero must first notarize it, pay taxes, present required documents, and pay fees before a new title may issue.

• Standing to Assail the Tax Delinquency Sale: Under Section 267 of the Local Government Code, the invalidation of a tax delinquency sale may be sought by the delinquent owner or by a person having legal interest in the property whose substantive rights have been impaired. In Alvarado vs. Ayala Land, Inc., et al., the Court ruled that the right to question a delinquency sale is not barred merely because the plaintiff is not the owner of the property sold. Salva vs. Magpile recognized that a tax delinquency sale derogates or impinges on property rights and due process, so the steps prescribed by law are mandatory and must be strictly followed. Caballero, as a prior purchaser of the property, would have her property rights impaired by an invalid tax delinquency sale that purports to transfer ownership to Laverne; this impairment is akin to a deprivation of property without due process of law. She therefore has sufficient legal interest to question the validity of the tax delinquency sale.

• Validity of the Tax Delinquency Sale: Section 258 of the Local Government Code requires the warrant of levy to be mailed to or served upon the delinquent owner of the real property or person having legal interest therein, or in case he or she is out of the country or cannot be located, upon the administrator or occupant of the property. The Court held that Section 258 requires actual notice to either the delinquent owner, or the administrator, or occupant of the property. In determining whether actual notice is required, the Court is guided by the character of the proceedings, which is determined by its purpose and by the language of the applicable statute. In Government of the Philippine Islands vs. Adriano, the Court distinguished in rem from in personam tax sale proceedings based on the applicable statute. In Pantaleon, et al. vs. Santos, et al., the Court held that tax delinquency sales under the Provincial Assessment Law were in personam because the law did not contain provisions binding the real estate and all persons having an interest therein, whether notified or not. In Spouses Tan vs. Bantegui and Talusan vs. Tayag, the Court ruled that tax delinquency sales under the Real Property Tax Code were in personam proceedings that required prior actual notice to the delinquent taxpayer, in addition to advertisement and publication. The relevant provisions of the Real Property Tax Code were substantially carried over to the Local Government Code. In Salva vs. Magpile, the Court ruled that actual notice of the warrant of levy to the delinquent owner is required because tax delinquency sales under the Local Government Code are in personam in nature and because Section 258 implicitly requires such actual notice. In the present case, nothing on record showed that Razote was actually notified of the Warrant of Levy sent to her by registered mail. The Officer-in-Charge of the Real Property Tax Division testified that even the Final Demand Letter, Reminder Letters, and Clarification Letter sent by the City Treasurer to Razote through registered mail were not received by anyone. Summons could not even be served on Razote because she supposedly moved out of her residential address in Makati years ago. There was also no showing that actual notice of the Warrant of Levy was received by any occupant or administrator of the property. The November 5, 2012 and January 2, 2013 Reminder Letters were received by Brittany Corporation, the developer of the property, but there was no showing that Brittany Corporation was the occupant or administrator of the subject property. At any rate, the Reminder Letters are different from the Warrant of Levy required by Section 258 to be actually received by the delinquent owner, or the occupant, or administrator of the property. Section 258 was therefore not complied with. Aside from Section 258, it did not appear that the other requirements of the Local Government Code had been complied with. Section 254 requires that the notice of delinquency be posted at the main hall and in a publicly accessible and conspicuous place in each barangay and published once a week for two consecutive weeks in a newspaper of general circulation. Section 258 further requires that written notice of the levy with the attached warrant be mailed to or served upon the assessor and the Registrar of Deeds, who shall annotate the levy on the tax declaration and certificate of title, and that the levying officer submit a report on the levy to the sanggunian concerned within 10 days after receipt of the warrant by the owner or person having legal interest. Section 260 mandates that within 30 days after service of the warrant of levy, the local treasurer shall proceed to publicly advertise for sale or auction the property by posting and publication. No evidence was adduced to prove compliance with these other requirements. The burden to prove compliance with the validity of the proceedings leading up to the tax delinquency sale is incumbent upon the buyer or the winning bidder, which in this case is Laverne, because a tax delinquency sale is in derogation of the property and due process rights of the owner. Laverne waived its right to present evidence in view of its repeated, unjustified failure to attend the Judicial Dispute Resolution proceedings. In view of Laverne's failure to discharge its burden of proving compliance with the Local Government Code's requirements for the valid conduct of a tax delinquency sale, the assailed tax delinquency sale is void. The Court recognized the difficulty in serving actual notice of the warrant of levy to delinquent taxpayers, especially where the taxpayer has already moved out of her registered address, but local treasurers are not without a remedy: they may file a civil action for collection under Section 266 of the Local Government Code and utilize the modes of service of summons under Sections 16 and 17, Rule 14 of the Amended Rules of Civil Procedure, together with the provisional remedy of preliminary attachment, as applicable.

• Applicability of Section 267 and Disposition of Deposit: Section 267 of the Local Government Code provides that in any action assailing the validity of a tax sale for non-payment of delinquent real property taxes, the taxpayer must first deposit in court the amount paid by the purchaser at auction, plus interest at the rate of two percent per month, or twenty-four percent per annum. If the sale is later declared invalid, the amount deposited shall be paid to the purchaser at the auction; otherwise, if the sale is declared valid, it shall be returned to the taxpayer. The purpose of the deposit is to reimburse the purchaser of the amount he or she had paid at the auction sale should the court declare the sale invalid, and to guarantee the satisfaction of the tax delinquency. In National Housing Authority vs. Iloilo City, et al., the Court explained that the deposit requirement is not a tax measure and held that it should not apply when the plaintiff is the government or any of its agencies, especially when the tax-exempt status of the plaintiff is acknowledged. In City Government of Tagaytay vs. Judge Guerrero, et al., the Court ruled that the deposit requirement in the precursor of Section 267 did not apply because the tax sale was not merely voidable but void, considering that the properties were situated outside the territorial jurisdiction of Tagaytay City. In Beaumont Holdings Corporation vs. Atty. Reyes, et al., the Court ruled that Section 267 does not apply because there was no tax delinquency to begin with and because it would be oppressive to require the taxpayer to comply with Section 267 when the deposit would amount to 49 to 76 times the tax demanded. Section 267 should not be sweepingly applied to any suit that questions the validity of a tax delinquency sale; it should be considered on a case-to-case basis. In the present case, none of the special circumstances present in the aforementioned cases are present. Unlike in City Government of Tagaytay and National Housing Authority, there is no dispute that Razote and the subject property are subject to the real property tax imposed by Las Piñas City. In Beaumont Holdings Corp., the Court refused to apply Section 267 because the real property tax appeared to have already been paid and because applying the provision would be unconscionable given the large amounts of interest involved. In contrast, Caballero does not claim that the real property taxes on the subject property were previously paid. Moreover, applying Section 267 here would result in an interest of only ₱10,042.39, which cannot be said to be oppressive in the same way as those involved in Beaumont Holdings Corp. Section 267 therefore applies, and the deposit of ₱26,239.80 should be released to Laverne.

• Issuance of a New TCT to Caballero: The Court cannot grant Caballero's prayer for the issuance of a new Transfer Certificate of Title in her name. Caballero's Deed of Absolute Sale, being unnotarized, is not yet a registrable document under Section 112 of Presidential Decree No. 1529. Once the Deed of Absolute Sale is notarized, she must first pay all the appropriate taxes on the sale, present to the Registry of Deeds the Deed of Absolute Sale and Razote's owner's duplicate certificate of title, and then pay the registration fee and other applicable fees, before the Deed of Absolute Sale is registered by the Registry of Deeds and a new title is issued in her name. The nullification of the tax delinquency sale is understood to be without prejudice to Las Piñas City's right to collect any unpaid real property taxes which may have accrued during the pendency of the case.

• Tax delinquency sale as an in personam proceeding — A tax delinquency sale under the Local Government Code is not a proceeding in rem; it is in personam. Consequently, actual notice of the warrant of levy must be given to the delinquent owner or person having legal interest, or, if they are out of the country or cannot be located, to the administrator or occupant of the property. Mere publication or registered mail that is not actually received does not satisfy the requirement. Noncompliance renders the sale void. The Court applied this because Razote did not actually receive the Warrant of Levy and no occupant or administrator was shown to have received it.

• Standing of a person with legal interest under Section 267 — Section 267 of the Local Government Code allows any person having legal interest in the property, not only the delinquent owner, to assail the validity of a tax delinquency sale, provided that his or her substantive rights have been impaired. A prior purchaser under an unregistered deed has such legal interest. The Court applied this to Caballero, whose property rights would be impaired by the invalid sale to Laverne.

• Burden of proving compliance with tax sale requirements — The burden to prove compliance with the validity of the proceedings leading up to the tax delinquency sale is incumbent upon the buyer or winning bidder, because a tax delinquency sale is in derogation of property and due process rights. The Court applied this to Laverne, which failed to present evidence and waived its right to do so.

• Section 267 deposit requirement and its exceptions — Before a court may entertain an action assailing the validity of a tax delinquency sale, the taxpayer must deposit the amount for which the property was sold plus two percent monthly interest. If the deed is declared invalid, the deposit is paid to the purchaser; if the action fails, it is returned to the depositor. The requirement is not applied sweepingly; exceptions exist where the sale is void for lack of jurisdiction, where the property is tax-exempt, where there is no tax delinquency, or where the deposit would be oppressive. The Court applied Section 267 because no such special circumstances existed and the interest was only ₱10,042.39.

• Registrability of unnotarized deeds — Under Section 112 of Presidential Decree No. 1529, deeds and other voluntary instruments must be executed as public instruments, acknowledged before a notary public or other authorized officer, to be registrable. An unnotarized deed of absolute sale is not registrable. The Court applied this to deny Caballero's prayer for a new Transfer Certificate of Title in her name.

• "The warrant shall be mailed to or served upon the delinquent owner of the real property or person having legal interest therein, or in case he [or she] is out of the country or cannot be located, the administrator or occupant of the property." — This is the statutory text of Section 258 of the Local Government Code, which the Court construed as requiring actual notice before a tax delinquency sale may be validly conducted.
• "Contrary to the ruling of the CA, the Court has previously held that Section 258 requires that actual notice must be given to either the delinquent owner, or the administrator, or occupant of the property." — This passage states the ratio decidendi on the notice requirement and directly rejects the CA's contrary interpretation.
• "From the foregoing, it is evident that tax delinquency sales under the LGC are in personam proceedings. Thus, actual notice of the warrant of levy should be given to the delinquent owner before his or her property is auctioned at a tax delinquency sale." — This is the Court's canonical formulation of the in personam character of tax delinquency sales under the Local Government Code.
• "The public auction of land to satisfy delinquency in the payment of real estate tax derogates or impinges on property rights and due process. Thus, the steps prescribed by law are mandatory and must be strictly followed; if not, the sale of the real property is invalid and does not make its purchaser the new owner." — Quoted from Salva vs. Magpile, this passage supplies the strict-compliance rule that justified voiding the sale.

• Alvarado vs. Ayala Land, Inc., et al., 818 Phil. 595 (2017) — Held that Section 267 grants the right to question a delinquency sale not only to the delinquent owner but also to any person having legal interest whose substantive rights have been impaired; relied on for Caballero's standing.
• Salva vs. Magpile, 820 Phil. 803 (2017) — Held that actual notice of the warrant of levy to the delinquent owner is required under Section 258 of the Local Government Code because tax delinquency sales are in personam; also held that strict adherence to tax sale statutes is mandatory. Relied on to void the sale.
• Government of the Philippine Islands vs. Adriano, 41 Phil. 112 (1920) — Distinguished in rem from in personam tax sale proceedings based on the applicable statute; used to establish that Philippine tax sale proceedings requiring personal demand and exhaustion of remedies are in personam.
• Pantaleon, et al. vs. Santos, et al., 101 Phil. 1001 (1957) — Held that tax delinquency sales under the Provincial Assessment Law were in personam and did not affect the rights of registered but undeclared co-owners; cited in the historical development of the in personam rule.
• Spouses Tan vs. Bantegui, 510 Phil. 434 (2005) — Held that tax delinquency sales under the Real Property Tax Code were in personam and required actual notice to the delinquent taxpayer; publication alone was insufficient. Cited to support the actual notice requirement.
• Talusan vs. Tayag, 408 Phil. 373 (2001) — Held that tax delinquency sales under the Real Property Tax Code were in personam proceedings requiring prior actual notice to the delinquent taxpayer; cited with Spouses Tan.
• National Housing Authority vs. Iloilo City, et al., 584 Phil. 604 (2008) — Explained that the Section 267 deposit is not a tax measure but a device to reimburse the purchaser and guarantee satisfaction of the tax delinquency; held the deposit did not apply to tax-exempt NHA. Cited in the Section 267 analysis.
• City Government of Tagaytay vs. Judge Guerrero, et al., 616 Phil. 28 (2009) — Held that the deposit requirement in the precursor of Section 267 does not apply to a void tax sale, such as where the property is outside the taxing authority's territorial jurisdiction. Distinguished because no such special circumstance existed here.
• Beaumont Holdings Corporation vs. Atty. Reyes, et al., 815 Phil. 584 (2017) — Held that Section 267 does not apply where there is no tax delinquency and the deposit would be oppressive; distinguished because Caballero did not claim prior payment and the interest here was not oppressive.
• Corporate Strategies Development Corp., et al. vs. Agojo, 747 Phil. 607 (2014) — Held that the burden to prove compliance with the validity of the proceedings leading up to the tax delinquency sale is on the buyer or winning bidder; cited to support Laverne's failure to discharge its burden.

• Section 258, Local Government Code of 1991 (R.A. No. 7160) — Requires the warrant of levy to be mailed to or served upon the delinquent owner or person having legal interest, or, if out of the country or cannot be located, the administrator or occupant; also requires notice to the assessor and Registrar and a report to the sanggunian. The Court held actual notice is required and noncompliance voided the sale.
• Section 267, Local Government Code of 1991 (R.A. No. 7160) — Requires a deposit of the amount for which the property was sold plus two percent monthly interest before an action assailing the tax sale may be entertained; the deposit is paid to the purchaser if the deed is invalid, returned if the action fails; invalidation is allowed only if substantive rights are impaired. Applied to require Caballero's deposit and release it to Laverne.
• Section 254, Local Government Code of 1991 (R.A. No. 7160) — Requires notice of delinquency to be posted and published; no evidence of compliance was presented.
• Section 260, Local Government Code of 1991 (R.A. No. 7160) — Requires public advertisement of the sale by posting and publication within 30 days after service of the warrant of levy; no evidence of compliance was presented.
• Section 266, Local Government Code of 1991 (R.A. No. 7160) — Allows the local government unit to enforce collection of real property tax through civil action; cited as the remedy available to local treasurers when actual notice cannot be served.
• Section 112, Presidential Decree No. 1529 — Requires deeds and voluntary instruments to be public instruments acknowledged before a notary public or other authorized officer to be registrable; applied to hold Caballero's unnotarized Deed of Absolute Sale not registrable.
• Section 53, Presidential Decree No. 1529 — Requires presentation of the deed and the owner's duplicate certificate of title for registration; cited as a step Caballero must follow.
• Section 111(C), Presidential Decree No. 1529 — Requires payment of registration fees; cited as a step before registration.
• Section 57, Presidential Decree No. 1529 — Governs issuance of a new title after registration; cited to deny Caballero's prayer for a new Transfer Certificate of Title.
• Section 58(E), Republic Act No. 8424 — Requires payment of appropriate taxes on sale; cited as a condition before registration of the Deed of Absolute Sale.
• Rule 14, Sections 16 and 17, Amended Rules of Civil Procedure — Provide modes of service of summons by publication and extraterritorial service; cited as available to local treasurers in a civil action for collection.
• Rule 57, Section 1, Amended Rules of Civil Procedure — Provides for preliminary attachment; cited as an available provisional remedy in a collection action.

Justices Inting, Gaerlan, and Singh concurred. Justice Dimaampao filed a separate opinion, the contents of which are not included in the provided text.