Miguel Reyes v. Remedios Delgado

Summary

This case involves the validity of a 1937 tax sale of a residential lot in Leyte. The heirs of original owner Severino Reyes challenged defendant Remedios Delgado's claim to the property, which was based on a tax sale to her predecessor-in-interest Benigno Delgado. The Court of Appeals affirmed the trial court's ruling that the tax sale was null and void ab initio due to the Provincial Treasurer's failure to comply with mandatory statutory procedures under Assessment Law Section 35, specifically the requirements for proper notice and advertisement. The court emphasized that tax sales, being in derogation of property rights and due process, require strict compliance with statutory procedures. The decision reinforced the constitutional principle that property cannot be taken except in accordance with due process, and that actions to annul void tax sales are imprescriptible.