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  • 5 Important Lessons from the Supreme Court Regarding a Broker’s Commission

    “Do not think of money. Just try to serve your clients. The money will come.”

    –  Jose E. Sabater, Real Estate Broker, Attorney and Author

    By Realttorney®

    Photo by Kampus Production on Pexels.com

    In a previous article, I said that a Listing Agreement or an Authority to Sell is the most important document that needs to be signed before marketing and selling any piece of real estate property. This is the concluding part of that article.

    It should be emphasized that a licensed real estate broker earns compensation only when he or she successfully procures a buyer who can complete the transaction at a price and on the terms and conditions that are stipulated in the Listing Agreement or Authority to Sell signed and executed by the owner-seller.

    There are 3 cases decided by the Supreme Court that we will highlight here. First is De Castro vs. Court of Appeals, G.R. No. 115838, July 18, 2002. Second is Manuel vs. Sarmiento, G.R. No. 173857, March 21, 2012. And third, Oriental Petroleum and Minerals Corporation vs. Tucsan Realty, Inc., G.R. No. 195481, July 10, 2013.

    It is encouraging to note that in all these 3 cases the Highest Court in the country awarded the real estate brokers the commissions that were withheld from them by the owner-sellers. But, as licensed real estate brokers, what are the lessons we can learn from these 3 cases?

    First, the Oriental Petroleum case reminds us of the principle of “procuring cause” in ordering the payment of the broker’s commission. The term “procuring cause” refers to a cause that starts a series of events and results, without break in their continuity, in the accomplishment of a broker’s prime objective of producing a purchaser who is ready, willing, and able to buy on the owner’s terms.

    Second, the Listing Agreement, whether exclusive or non-exclusive, is a contract of agency. Hence, if the Agreement is not contrary to law, public order, public policy, morals, or good custom then it is a valid contract and constitutes the law between the parties. This is according to De Castro vs. Court of Appeals.

    The basic job of the broker is to locate a person (natural or juridical) who is ready, willing, and able to buy the real property registered in the name of the owner-seller, with the end goal of consummating the sale.

    As such, the contract of agency executed by the owner-seller and the real estate broker should be complied with following its terms and conditions in good faith. However, it must be recognized that the owner-seller has the right to revoke the Agreement at any time. Now, this leads us to our third important point.

    The Court (in the Oriental Petroleum case) has always recognized the real estate broker’s right to his commission, although the owner revoked his authority and directly negotiated with the buyer whom he met through the broker’s efforts.  It would be unfair not to give the broker the reward he had earned for helping the owner find a buyer who would pay the price. So, make sure that there is a hold-over provision in the contract of agency.

    Fourth, care must be taken to ensure that the Authority to Sell was validly executed. It must be emphasized that the authority to sell in the case of Manuel vs. Sarmiento was notarized. Take note that a notarized document has in its favor the presumption of regularity and can be contradicted only by clear and convincing evidence.

    Fifth and final point, when one has secured an exclusive authority to sell it is incumbent upon the broker to serve his or her principal well. The effort expended should be commensurate to the professional fee agreed upon by the owner-seller and the broker.

    In the case of Manuel vs. Sarmiento, the broker went out of her way to spend for the survey of the land, the reconstitution of the title of the property that was sold, and paid for the real property taxes and tax clearances. These are mere examples of “going the extra mile” for the interests of a particular client.

    As mentioned before, the Supreme Court has always defended the right of the real estate broker to his or her commission as against an owner-seller, who thinks of fraud and deceit towards the service provider. The Listing Agreement or Authority to Sell (if drafted correctly) is designed to protect the real estate broker from scheming sellers who think it is convenient to disregard the broker just to save and pocket more money for themselves when the sale is consummated.

    Think less of the compensation and let us focus on serving our clients to the best of our talents and abilities. Yet, it doesn’t hurt if we have a good Listing Agreement or Authority to Sell in place to protect us from any eventuality. The best evidence in court is a notarized contract of the agency that will serve to protect the rights of the real estate broker when the owner-seller decides to deploy bad faith and intentionally breaches the contract in the name of cost-saving.

    So, are you the type of licensed real estate broker who fails to secure a signed Listing Agreement or Authority to Sell and just proceeds to market the property? If yes, then you may want to consider the insights provided by this article.

    If you know someone who has experienced being screwed over by an owner-seller, let me know so we can discuss what safeguards can be deployed to counter any bad intentions of the owner-seller toward a licensed real estate broker. As a matter of principle, suing your client is not the best way to end a transaction. But, we must also be assured that as licensed professionals we are compensated based on the agreement with the owner-seller.

    Finally, I am writing a book entitled “The Law & Jurisprudence on Compensation in Real Estate Brokerage in the Philippines” which will be published in the second quarter of 2024. It gives the history of how real estate brokerage began in the 1900s under the American colonization period, what laws regulated the practice from the 1900s to the present, and the right to compensation of licensed real estate brokers. Let me know if you desire to have a copy of the book. Leave a comment below. God bless always.

    ——-

    Atty. Jojo is a real estate attorney, an estate planning attorney, a licensed real estate broker, and a PRC-accredited Lecturer/ Speaker for Training Programs in Real Estate. He is committed to helping new and veteran real estate service practitioners be well-informed of the latest laws, rules, regulations, and information relevant to the real estate service sector.

  • The Most Important Document You Need Before Selling Any Real Estate

    Documents create a paper reality we call proof.

    – Mason Cooley, American literary academic and aphorist

    By Realttorney®

    This is an article that was first published last April 22, 2015, before I lost my domain name in April 2020 at the start of the pandemic. But now it is back. And I am slowly uploading the various articles that were previously published and updating them. The updates are in green font.

    Last January 2015, I got a text message from two colleagues about a similar concern. Both of them were having a problem with the exclusive authority to sell extended to them by their respective owner-sellers.

    MHS was upset that a licensed broker refused to acknowledge her exclusive authority to sell signed by the owner of the property. The buyer of MHS got outbid by a higher purchase price of the buyer of this broker. The other broker said that there was nothing in the law that would dictate how they would share the commission.

    Meanwhile, VB mentioned that she has exclusive authority to sell a property signed by the owner. But she asks what is the arrangement if the owner himself finds a buyer for the property? Her authority does not contain any provision on such an instance.

    The problems of MHS and VB are quite the norm concerning the exclusive authority to sell. However, most licensed real estate brokers in the Philippines overlook or forget to undertake certain steps to protect themselves from unscrupulous owner-sellers and unethical brokers.

    A dutiful real estate broker should always execute a Listing Agreement with the owner-seller before exerting any efforts to market and sell the property. This is the most important document that needs to be secured first and foremost. Numerous licensed real estate brokers forget this very important piece of document that governs the relationship between the licensed real estate broker and the owner-seller.

    I have overlooked this document several times in the past in my eagerness to market, advertise, and put up for sale a particular piece of property. Most often, this happens when the owner-seller is a good friend or a close client of mine.

    But I would say now that no matter what your relationship is with the owner-seller, the number one order of the day for all licensed real estate brokers is to draft a Listing Agreement and have it signed by the owner-seller. This becomes especially important when the owner-seller is a stranger to the broker.

    A Listing Agreement is a binding legal document executed by and between the owner-seller and the licensed real estate broker that governs the relations of the parties regarding the marketing and sale, lease, or mortgage of a property and the professional fees due to the latter when there has been a successful consummation of the transaction.

    It is a contract whereby there is a meeting of the minds between the owner-seller and the real estate broker, and the former binds himself or herself to pay the agreed-upon professional fee while the latter renders the service enumerated in the agreement itself.

    There are several types of Listing Agreements as to exclusivity. The first is open listing or non-exclusive. This type is where the seller lists the property to several or many brokers. This type also allows the owner the right to sell the property himself without paying any professional fees to brokers who have already exerted efforts to market the property and find buyers for it.

    The second is an exclusive agency where the owner-seller agrees to list the property to only one broker during the listing period but reserves the right to sell his/her own property without the obligation to pay a professional fee to the said exclusive broker. During the initial meeting with the owner, the real estate broker must be able to determine if the owner-seller is unwilling to give up the right to sell the property by himself or herself.

    If this is the case, then my advice would be not to take on the task of marketing and selling the real property. Oftentimes, owner-sellers who are unwilling to let the real estate broker perform the services he or she enumerated on the exclusive agency are a control freak. As such, this translates into misunderstandings between seller and broker regarding compensation. 

    Finally, we have the exclusive listing (or exclusive authority to sell) which is the agreement that grants a particular real estate broker the right to sell the property during the listing period and payment of the professional fee is absolutely due to the broker in all instances when the property is sold, even if by the owner himself.

    Unfortunately, there are owner-sellers out there who do not honor their agreements with their licensed real estate brokers. On the other end of the spectrum, you have licensed brokers who likewise do not honor the terms of the exclusive authority to sell, like in the case of MHS.

    Here is a practical and ethical tip. As a buyer’s broker, you should inquire from the seller’s broker what type of agreement he or she has with the owner-seller. And please, ask for a copy for your study and reference. Thereafter, respect the agreement because that is the legal and ethical thing to do. [See Section 2, Article II and Section 4 (a), Article III, Code of Ethics and Responsibilities for Real Estate Service Practitioners – PRBRES Resolution No. 39, Series of 2019]

    But, oftentimes, the owner-seller and the rival brokers take a chance to disregard the exclusive listing simply because the said agreement was not properly explained by the exclusive selling broker to the owner-seller. Hence, real estate broker must be able to fully explain to their clients what type of agreement and the various nuances behind each.

    In the past, I have been approached by a lot of licensed real estate brokers asking if they can sue the owner-seller for reneging on the obligation of the exclusive authority to sell. My advice is always to dissuade that colleague from filing a case against the owner-seller because most often the listing agreement is not airtight or there is no agreement to begin with.

    The Supreme Court has promulgated several cases where exclusive listing agreements and simple contracts have been upheld and owner-sellers have been directed to pay the outstanding professional fees due to the real estate broker.

    But that would be another article for the future. I am also writing a book entitled “The Law & Jurisprudence on Compensation in Real Estate Brokerage in the Philippines” which will be published in the second quarter of 2024. It gives the history of how real estate brokerage began in the 1900s under the American colonization period, what laws regulated the practice from the 1900s to the present, and the right to compensation of licensed real estate brokers. Let me know if you desire to have a copy of the book. Leave a comment. Thank you.

    ——-

    Atty. Jojo is a real estate attorney, an estate planning attorney, a licensed real estate broker, and a PRC-accredited Lecturer/ Speaker for Training Programs in Real Estate. He is committed to helping new and veteran real estate service practitioners be well-informed of the latest laws, rules, regulations, and information relevant to the real estate service sector.

  • The Most Important Personal Quality A Licensed Real Estate Broker Needs To Be Successful in the Real Estate Service

    Integrity is doing the right thing, even when no one is watching.

    C.S. Lewis, British Writer & Literary Scholar

    By Realttorney®

    For those planning to take the Real Estate Broker’s Examination in April 2024, this will give you perspective on how you should act and what the future holds for you in a business that is based on the network and relationships you build at the beginning and all throughout your career.

    This is an offshoot of my lectures on the Code of Ethics for Real Estate Service Practitioners. I have always said that the real estate service profession is relationship-based. How people perceive you or the kind of reputation you build as you embark on your career will determine how long you will last.

    This article is written for those graduating with their degree in Bachelor of Science in Real Estate Management in 2024, as well as those newly accredited Real Estate Salespersons and newly licensed Real Estate Brokers.

    What then is the answer to the title of this article?

    The most critical personal quality for a successful real estate broker is unwavering integrity. In a profession built on trust, clients seek assurance that their interests are paramount.

    Integrity is the bedrock of ethical conduct, ensuring transparent transactions and fostering lasting relationships. A licensed real estate broker’s commitment to honesty and ethical practices not only safeguards the client’s interests but also enhances the reputation of the entire real estate industry.

    Integrity establishes credibility, allowing a broker to navigate challenges with trust and professionalism, ultimately defining success through a legacy of reliability and client satisfaction.

    The quote by Clive Staples Lewis underscores the importance of unwavering integrity in one’s actions, aligning with the ethical foundation essential for success in the real estate service sector. Additionally, it reflects the commitment to principled conduct, emphasizing that true integrity is demonstrated consistently, regardless of external scrutiny or financial gains.

    What is the next most important personal quality?

    In addition to unwavering integrity, effective communication stands out as a bonus quality crucial for success in real estate brokerage. Clear and timely communication is the linchpin of client relationships and successful transactions.

    A broker’s ability to articulate complex real estate concepts, market trends, and negotiation strategies instills confidence in clients. Moreover, active listening skills enable brokers to understand clients’ needs and preferences, fostering a more personalized and satisfactory experience.

    How can these qualities be demonstrated in what licensed real estate brokers do and the opportunities that come along with them?

    So, what do licensed real estate brokers do? Well, that answer can be found in Paragraph (4) (G), Section 3 of Republic Act No. 9646, otherwise known as the “Real Estate Service Act of the Philippines.” It states that a real estate broker is a duly registered and licensed natural person who, for a professional fee, commission or other valuable consideration, acts as an agent of a party in a real estate transaction to offer, advertise, solicit, list, promote, mediate, negotiate or effect the meeting of the minds on the sale, purchase, exchange, mortgage, lease or joint venture, or other similar transactions on real estate or any interest therein.

    Simply put, the real estate broker is the middle person between the two parties wanting to make a deal or consummate a real estate transaction. What transactions, you ask? It could be a sale, purchase, exchange, mortgage, lease or joint venture project, or similar transactions on real estate or any interest therein.

    What then are the opportunities for a newly licensed real estate broker? Easily, engaging in real estate brokerage is the most obvious one. A new real estate broker can apply with established real estate development companies to market existing projects all over the country.

    Or the newbie can set out on his/her own and be an independent real estate broker seeking out listings from sellers of real property. The newbie can do this for a couple of years until he/she is ready for the next step in his/her career in real estate.

    As they gain experience, the newbies are exposed to unethical behavior or other RESPs or are tempted to perform unethical actions by the sellers or buyers themselves. Under PRBRES Resolution No. 39, Series of 2019, working with unlicensed individuals is unethical. Likewise, sharing one’s compensation with a “colorum” practitioner is unethical. Therefore, the new real estate brokers must stand their ground and resist all attempts at performing unethical acts.

    When I deliver the lecture on the Code of Ethics to aspiring real estate salespersons, I always say to the attendees that I will not judge them for the acts that they did in violation of the Code of Ethics or Rep. Act No. 9646. But, I tell them that if they get caught they have to bear the consequences of their acts. Therefore, maintaining unwavering integrity is key to one’s career longevity.

    Meanwhile, not being able to properly communicate legal principles and the pros and cons of the real estate transaction at hand is a great disservice by the real estate brokers to their clients. It goes without saying that a good communicator is humble, honest, and straightforward. The real estate broker must call a spade a spade with or without embellishment. Enough of the “sales talk” and the B.S. to the clients.

    The passion one has for real estate and its vast earning opportunities must always be tempered by unwavering integrity and effective communication skills. Through a combination of integrity and adept communication, a real estate broker not only builds trust but also cultivates a reputation as a reliable and client-centric professional, essential for sustained success in the dynamic real estate industry in the Philippines.

    ——-

    Atty. Jojo is a real estate attorney, an estate planning attorney, a licensed real estate broker, and a PRC-accredited Lecturer/ Speaker for Training Programs in Real Estate. He is committed to helping new and veteran real estate service practitioners be well-informed of the latest laws, rules, and regulations, and information relevant to the real estate service sector.

  • 3 Crucial Steps to Creating Extra Time in a Day

    “Starting your day early gives you an immense advantage. It boosts your energy, puts you ahead of the rest of the pack, and allows you to be better organized so success will come more easily.”

    – Michael Masterson, creator of Early to Rise

    By Realttorney

    If you are at a loss on how to make 2024 your best year in real estate, you can read the article I wrote regarding this topic. The tips written there can be used and applied in all endeavors not just real estate.

    Since we all have the same 24 hours given to us, how we use our time determines whether the goals we set for ourselves are accomplished or not during the period we allocate.

    Way back in 2003, I subscribed to a newsletter from an author who wrote daily articles based on the motto of Benjamin Franklin: “Early to bed and early to rise, makes a man healthy, wealthy, and wise.” It was written by Michael Masterson (a pen name) and the website is Early to Rise (ETR).

    I read his articles and it fascinated me immensely. He became my unofficial mentor in the aspects of goal-setting, time management, and wealth-building.

    I subscribed to his newsletter and purchased his books. I also joined the 2007 Total Success Achievement Program of ETR. This article is inspired by one of the weekly Power Surge Messages that was emailed to the participants by Robert L. Cox, the Success Mentor of the said Program.

    What is the most common reason why goals are not accomplished? Lack of time. I am very familiar with this and have used this reason as an excuse to explain why my goals have not been achieved year after year.

    How can you overcome this great obstacle of “lack of time” and achieve more this 2024? By creating time. But, this is not to say that we will be having a 25-hour or 26-hour day. That is quite impossible.

    Robert Cox said, “Successful people know how to ‘create time’ by using their time better than the majority of the population.” Therefore, if you want to be successful you should be able to know how to create time.

    But, there have been other articles written about the topic of finding more time in a day. One of these is written by my then unofficial mentor Leo Babauta – the creator of Zen Habit.

    What are the 3 crucial steps to creating extra time in a day?

    First, get up an hour earlier each morning. According to Michael Masterson, “The extra time gives you a tremendous advantage over everyone and everything you compete against.” This resonates with me because I am a morning person. I cherish the quiet time each morning while my wife and children are still fast asleep.

    I don’t waste this golden hour. I perform my morning routine. I meditate, pray, read my vision and mission statements, review my plan for the day as well as revisit my weekly and monthly goals.

    Leo Babauta wrote the “10 Benefits of Rising Early, and How to Do It” way back in May 2007. I fully subscribe to the 10 benefits that he listed. It is a great article because Leo also gave 8 tips on how to become an early riser.

    For this year, I want to establish the habit of writing for 60 minutes for the books, blog articles, and scripts for the videos within this golden hour. I think this is the missing link that will elevate the execution of my monthly plans and accomplish my goals efficiently.

    Second, become better organized. By waking up early in the morning, I can review my weekly and monthly goals and recalibrate them based on the progress or setbacks that I have encountered daily. Why? Because life happens. That’s why?

    As you get better organized, you become more efficient with the use of your time. Tasks that take an hour to do, may be accomplished in just half the time. In effect, you gain an “extra” 30 minutes to use for the completion of other tasks or goals.

    Third, determine your definiteness of purpose in life. The phrase “definiteness of purpose” was coined by Napoleon Hill in his book “Think and Grow Rich.”

    Mr. Hill said that definiteness of purpose is the starting point of all achievement, and its lack is the stumbling block for ninety-eight out of every hundred people simply because they never really define their goals and start toward them.[1]

    “Definiteness of purpose develops self-reliance, personal initiative, imagination, enthusiasm, self-discipline, and concerted efforts. All these are required for success… Once you have determined your definite major purpose, you will begin to budget your time, your money, and all your day-to-day endeavors so that they will lead to the attainment of your major purpose. Time budgeting always pays dividends because each moment is made to progress toward your goal…”[2]

    Knowing your definite major purpose focuses all your efforts toward the achievement of that purpose. Therefore, it is easier to give up binge-watching various Netflix series, or mindless surfing the internet.

    If you are a news junky like me, it will be easier to stop reading the newspaper and watching the news on TV if you have identified your definite major purpose.

    All the time that you gain from giving up watching Netflix, YouTube, and surfing the internet can be redirected towards achieving your goals. And that is one of the major advantages of having a definiteness of purpose.

    These 3 crucial steps can be individual topics that can be discussed lengthily in an essay. But, it is important to know and implement these 3 steps to have more time on your hands in the pursuit of your goals.

    Following them will guarantee your success in all aspects of your life. Try them out, you have nothing to lose.

    [1]“Napoleon Hill’s Keys to Success: The 17 Principles of Personal Achievement,” Edited by Matthew Sartwell, New York, Plume, October 1997, page 1.

    [2]Ibid., pages 3-4.

    ——-

    Atty. Jojo is a real estate attorney, an estate planning attorney, a licensed real estate broker, and a PRC-accredited Lecturer/ Speaker for Training Programs in Real Estate. He is committed to helping new and veteran real estate service practitioners be well-informed of the latest laws, rules, regulations, and information relevant to the real estate service sector.

  • How To Make 2024 Your Best Year in Real Estate

    “Accomplishing a goal has three phases: deciding to do it, determining what specific actions are necessary and in what order, and executing those actions.”

    – Michael Masterson, Best-selling Author and Entrepreneur

    By Realttorney®

    From my family to yours, we wish you the merriest and happiest Christmas! It is ten days before Christmas day, and everyone is busy preparing for the holiday festivities. Excluding today there are only eight working days left in 2023.

    As we close the year 2023, we look expectantly toward 2024 and the vast opportunities it brings to be of service to clients, friends, family members, and our community. We want to “hit the ground” in 2024 running and shake off the effects of a long holiday break.

    I am sure most of us were unable to accomplish all our goals in 2023. Hence, we look to the next year to continue our quest to finish what we started in 2023. For those who have accomplished all that they set to do in 2023, we congratulate you for your tireless and focused efforts.

    So how do you make 2024 your best year in real estate? Here are three (3) steps we suggest you do.

    First, CONDUCT A YEAREND REVIEW. Go over your physical or digital daily planner to see the numerous activities and projects completed and uncompleted during the year. If you have a journal where you list all your goals, then read them and determine why you succeeded in a particular goal or project and why you failed in another.

    I am old school, so I have a traditional To Do List which is not really ideal from what I have recently read in articles and watched on YouTube over the past month. But, my Life Plan is on my laptop and it serves as a compass in the journey of my life, as a husband, father, attorney, real estate broker, and a law-abiding Filipino.

    It is a great activity to do especially towards the end of the year. It only takes 20 minutes or longer, depending on you. With a pen and paper, find a quiet place to sit back and reminisce on the year that is about to end.

    Take note of the goals, projects, and tasks that were not started, started but not concluded. What could have been the reasons for such failures or missteps? Reflect on these reasons.

    Oftentimes, the number one reason for me not accomplishing a particular goal or project is the lack of time. Another is over enthusiasm which leads to setting too many goals and thinking it can be accomplished all at the same time.

    The second step is what I call GOAL-ORIENTEERING. This is the time to set new goals or to re-orient your existing goals. Dr. Maxwell Maltz, author of “Psycho-Cybernetics” likened a human being to a bicycle: we maintain our balance only while we are moving toward something. Trying to maintain balance while sitting in one place makes us feel shaky and, ultimately, we fall.

    Dr. Maltz says that if we have no worthwhile personal goals, it is easy to conclude that life itself is not worthwhile. It is only by establishing specific attainable goals that we turn our servomechanism into a success mechanism.

    There are dozens upon dozens of self-help books discussing how to effectively set goals. I have written about goal-orienteering in a previous article.

    But, Dr. Maltz emphasized that setting goals that are fulfilling and achievable requires a SMART approach –

    S-pecific

    M-easurable

    A-chievable

    R-elevant

    T-imebound

    Taking the SMART approach, make a list of all your goals for the coming year. Don’t worry about how long your list will be. Just write down all that your heart and mind desire.

    Then, prioritize these goals based on your core values and beliefs. Choose 2 to 3 major goals for the year that will improve your health, wealth-building abilities, personal or intellectual development, and family or social relationships. This approach is a suggestion of Michael Masterson, the creator of Early to Rise, which some have fully embraced.

    Write your goals down and be SPECIFIC. Thereafter, break down your yearly goals into monthly goals. Then break down the monthly goals into weekly goals. After identifying your weekly goals, create your DAILY PLAN OF ACTION. Determine how much time you are willing to commit to fulfilling each and every goal in your plan.

    Set specific deadlines for achieving the goals/completing the task and lay out the details of the plan to achieve these goals. If it’s too large a goal, break it down into sub-deadlines and write them down in order. It is important to organize the items on your list into a plan by placing them in the proper sequence and priority.

    Next, set aside time every day to work towards these important goals. Dwayne Baptist in his book “5 Secrets of Goal Setting” says FOCUSED ACTION is the basic key to achieving success. Set aside at least an hour of your day to follow what is suggested above to come up with a plan that you can implement for the entirety of 2024. And, with your Plan of Action in place, you are ready to execute it with focused action.

    The third step is to CREATE A FEEDBACK MECHANISM. Monitor your progress by keeping a journal of every action taken towards achieving your goals. I just purchased a simple notebook to use as my journal for this purpose.

    It is extremely important to set up a structure for how you will record your daily efforts. Keeping a record in a Goals Journal (for example) of the many steps you achieved is a must so that you can review your accomplishments a week or two before the end of every quarter. this could be in written or digital form. It is up to you.

    I do a quarterly review of my progress. Why? Failures will abound. This I know very well. In the last two decades, there have been a lot of unaccomplished goals for me. So, plan to fail. Not everything will go well. But, focus on the journey and how you will be transformed by the entire process.

    For this coming year, I will take a less active role in litigation and plan for more content creation as a service to licensed real estate brokers and accredited real estate salespersons – rookies and veterans alike. In 2024, I plan to publish and launch a minimum of three books. In 2024, I plan to be active in real estate brokerage as well as begin and finish the development of some real estate projects in Indang, Cavite.

    My motto at the beginning of 2024 is “If you want different results… start doing things differently.” Follow the 3 steps listed above and welcome the New Year with renewed vigor. And, for a more detailed approach to creating your ultimate real estate prosperity plan in 2024, you can click on the underlined words.

    But, I leave you with a warning. Executing your Plan as you designed it following the 3 steps here is hard, hard work. So, aside from planning to fail, plan for some rest and recreation as a reward for yourself and your family with every major success you will have.

    Let me know what your grand plans are this coming 2024. Happy holidays. Enjoy the company of relatives and friends in the last 2 weeks of 2023.

    ——-

    Atty. Jojo is a real estate attorney, an estate planning attorney, a licensed real estate broker, and a PRC-accredited Lecturer/ Speaker for Training Programs in Real Estate. He is committed to helping new and veteran real estate service practitioners be well-informed of the latest laws, rules, and regulations, and information relevant to the real estate service sector.