- Petitioner
- Herminio M. de Guzman
- Respondent
- Tabangao Realty Incorporated
- Citation
- G.R. No. 154262
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Leonardo-De Castro, J.
- Decided
- February 11, 2015
Summary
The heirs of spouses Serafin and Amelia de Guzman filed an action to quiet title against Tabangao Realty Inc., challenging the validity of a Sheriff's Certificate of Sale covering their inherited property. The property was sold at execution sale in 1988 to satisfy the spouses' debt to Filipinas Shell Petroleum Corporation, and the one-year redemption period expired without redemption. The trial court dismissed the complaint for failure to state a cause of action, finding the execution sale valid. The Supreme Court affirmed, holding that petitioners lacked legal title since all rights to the property passed to respondent upon expiration of the redemption period. The Court ruled that petitioners' allegations challenging the sale's validity were mere conclusions of law without factual basis, and that procedural rules on execution sales could be applied retroactively to pending cases.