Bureau of Internal Revenue v. Tico Insurance Company

Summary

This case involved competing priority claims over TICO Insurance Company's condominium units between the BIR's tax lien and Glowide/PMI's attachment and execution rights. The Supreme Court affirmed the Court of Appeals decision favoring Glowide and PMI, ruling that their attachment rights, which retroact to December 22, 2000, are superior to BIR's tax lien annotated on February 15, 2005. The Court emphasized that under Tax Code Section 219, tax liens are not valid against judgment creditors until notice is filed with the Register of Deeds. The Court also found that TICO's interpleader complaint was improper as it constituted a collateral attack on the final and executory judgment in favor of Glowide and PMI. The decision clarifies the hierarchy of preferred credits, distinguishing between special preferred credits (attachment/execution) and ordinary preferred credits (general tax claims) under the Civil Code.