Rep. Of Philippines (represented by Asset Privatization Trust) vs. NLRC RP/APT, petitioner v.

NLRC et al, defendant Doctrine: Law provided that redemption period is 12 months. 12x30=360. NOT 365 days. According to the rules of computation of Article 13. Article 13s computation of 12 months is not necessarily equivalent to 1 year. Date: 1999 Ponente: Pardo, J. Short version: On Dec 27, 1974, PNEI (Pantranco North Express Inc.) obtains a $500,000 form NDIC (National Investment Development Corporation), a subsidiary of PNB. As security, PNEI mortaged parcels of land in favor of NIDC, including Pantranco Bus Terminal in Tarlac. In 1991, DOTC took over operations of PNEI, but due to the demands of PNEIs labor unions, the company was unable to continue operations. The 2 unions asked the labor arbiter to intervene so they can collect claims. PNEIs assets were sold at public auctions, including the Pantranco Bus Terminal in Tarlac. On October 24, 1994, sherrifs issued a certificate of sale for Domingo P. Uy for the Tarlac terminal. 364 days later, APT tried to redeem the property, supposedly within the 12 months it was allowed to do so. APT asked SC to nullify Labor Arbiter and NLRCs decisions to void APTs redemption of land in favor of public auction winner Domingo P. Uy as it contends that it was able to make the claim within the 12 months specified. Labor arbiter and NLRC award the property to Uy because of Art. 13 (12 months=30 days/month=360 days). APT tried to claim on 364 th day. 4 days late. SC denies petition and affirms labor arbiter and NLRC decisions. Issue: Whether the period of redemption in auction sale on execution under Section 30, Rule 39 of the 1964 Revised Rules of Court is twelve (12) months or one year from the date of registration of the sale with the register of deeds. Held: The redemption period is 12 months, not one year, from the date of sale. Ratio: We rule that the period of redemption of real property sold on execution under Section 30, Rule 39, 1964 Revised Rules of Court is twelve (12) months, not one year, from the date of the sale. What is here in question, instead, is the computation of the redemption period of twelve (12) months. Applying Article 13 of the Civil Code, the redemption period in this case (under Section 30, Rule 39 of the 1964 Revised Rules of Court) consists of three hundred sixty (360), and not three hundred sixty five (365) days. Section 30 provided only twelve (12) months, which under the rules of computation in Article 13, Civil Code, is not necessarily equivalent to one year. With this ruling, we regret that petitioner failed to redeem the subject property within the twelve-month redemption period prescribed under the rule then in force.