Short answer. Yes. Rule 39, Section 15 requires notice before any execution sale: posted written notice — twenty days in three public places for real property, at least five days for other personal property — newspaper publication where realty's assessed value exceeds P50,000, and, in all cases, written notice to the judgment obligor at least three days before the sale.
What the law says
In all cases, written notice of the sale shall be given to the judgment obligor, at least three days before the sale
Rule 39, Section 15 — Notice of sale of property on execution. Read the full provision →
What the law says
In case of real property, by posting for twenty days in the three public places above- mentioned a similar notice particularly describing the property and stating where the property is to be sold
Rule 39, Section 15 — Notice of sale of property on execution. Read the full provision →
Posting, graduated by the kind of property
The section opens flatly: Before the sale of property on execution, notice thereof must be given. The posting requirement then scales with the property. Perishable property calls for written notice of the time and place of sale in three public places — preferably in conspicuous areas of the municipal or city hall, post office and public market — for such time as is reasonable given the property's condition. Other personal property requires the same posting for not less than five days. Real property demands the most: posting for twenty days, with a notice particularly describing the property and stating where the property is to be sold.
Publication for higher-value real property
Where real property is to be sold and the assessed value of the property exceeds fifty thousand (P50,000.00) pesos, posting alone is not enough. The notice must also be published once a week for two consecutive weeks in one newspaper selected by raffle — in English, Filipino or a major regional language — published, edited and circulated in the province or city, or in the absence of one, having general circulation there. The raffle detail is not decoration: it removes the choice of newspaper from the parties and the sheriff alike, which protects the process from a notice quietly placed where nobody would see it.
Personal notice to you, and the sale's fixed frame
Beyond the public notices, the section is explicit that the judgment obligor is told directly: In all cases, written notice of the sale shall be given to the judgment obligor, at least three days before the sale, served in the same manner as personal service of pleadings — for perishable property, at any time before the sale. The notice must specify the place, date and exact time of the sale, which must fall between nine in the morning and two in the afternoon. The parties may agree on the place; absent agreement, real property and personalty not capable of manual delivery are sold at the office of the clerk of court that issued the writ, while movables are sold where they are located.
Why the details are worth checking
Every requirement in this section is concrete and verifiable after the fact: where notices were posted and for how long, whether publication ran for the two weeks, when the written notice reached you, whether the sale happened at the stated hour and place. If your property is headed for auction, keep contemporaneous records against each item on that list — and if a sale has already occurred, those same details are the first thing counsel will reconstruct, because a sale conducted outside what the rule commands is a sale with a defect at its foundation.