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  • Rep. Act No. 12216: Game Changer for Socialized and Low-cost Housing?

    “Housing is absolutely essential to human flourishing. Without stable shelter, it all falls apart.”

    – Matthew Desmond, Sociologist & Professor in Princeton University

    (Part 1 of 2)

    By Realttorney®

    The Philippine socialized and low-cost housing landscape is set for a significant shift with the passage of the “National Housing Authority Act” (Rep. Act No. 12216). This landmark legislation repeals Presidential Decree No. 757 and serves as the new charter for the National Housing Authority (NHA), the primary national government agency engaged in direct housing production.

    The Act aims to ensure a continuing and sustainable program for urban land reform and housing, making affordable and decent housing available to underprivileged and homeless citizens. The passage of this new law is a critical step towards addressing the nation’s enduring housing backlog, now estimated at around 6.5 million units.

    For real estate professionals charting the course in this evolving sector, and for potential homebuyers navigating their options, a thorough understanding of RA 12216 is indispensable. This Act brings forth significant changes – some empowering, others presenting new challenges. Let’s explore its key provisions and critically analyze its potential impact.

    Let us now delve into its key provisions and critically assess its potential impact on various stakeholders.

    📖 Eight Pillars: Key Provisions Strengthening the NHA

    This Act lays down several crucial provisions designed to enhance the NHA’s capacity and effectiveness:

    ✅ Renewed Mandate with Built-in Accountability [Sections 4 & 25]

    The NHA shall continue to exist and operate under this new Act for another twenty-five (25) years, commencing July 31, 2025. This term is subject to a mandatory review every five (5) years by the Department of Human Settlements and Urban Development (DHSUD), Commission on Audit (COA), and the Governance Commission for GOCCs (GCG). This review will evaluate performance and organizational structure, potentially recommending reorganization, consolidation, or even abolition.

    This extension is fundamental. The 25-year term provides a substantial horizon for strategic planning and program implementation. However, the 5-year mandatory review introduces a critical layer of accountability. It provides the NHA with the long-term stability essential for planning, implementing, and sustaining multi-decade housing strategies. For real estate professionals, this signals a more consistent government presence in the socialized housing sector, potentially leading to more predictable long-term partnerships and development frameworks. It could also mean a more adaptive and performance-driven NHA.

    For homebuyers in NHA’s target demographic, it offers the prospect that NHA’s programs will be regularly assessed for effectiveness, using indicators like housing production, occupancy rates, collection efficiency, and beneficiary feedback. This mechanism aims to ensure the NHA remains responsive to the evolving housing needs and maintains public trust.

    ✅ Boosted Financial Foundation: Increased Capitalization [Section 5]

    The authorized capitalization of the NHA is significantly increased from Five billion pesos (P5,000,000,000) to Ten billion pesos (P10,000,000,000), to be fully subscribed and paid by the Republic of the Philippines.

    This doubling of authorized capital provides the NHA with a more robust financial base to undertake larger-scale housing projects and programs. This increased financial capacity is crucial for addressing the substantial housing backlog and could translate into more housing units developed and more families served. For the real estate sector, a financially stronger NHA could be a more reliable partner in potential (though now differently incentivized) joint ventures and a more significant player in land development for socialized housing.

    ✅ Comprehensive Community Development and Enhanced Housing Operations [Section 6 III]

    The NHA is mandated to develop and implement comprehensive housing programs, including upgrading informal settlements, producing shelters for the underprivileged (with grants and socialized housing), resettling informal shelter families (ISFs) from danger areas and infrastructure projects, and providing housing for low-income government employees. A key aspect is undertaking housing development through joint ventures or Public-Private Partnerships (PPPs) to ensure sustainable livelihood programs, job opportunities, and the construction of basic community facilities and utilities (power, water, ICT). The Act also emphasizes strengthening the participation of affected families from social preparation to resettlement and making housing plans publicly available for comment.

    With this new task of the NHA, a closer coordination on creating policies and strategic plans or roadmaps for creating human settlements with the Department of Human Settlements and Urban Development (DHSUD) is called for, in line with the latter’s mandate pursuant to Rep. Act No. 11201.

    This marks a crucial philosophical shift from merely constructing housing units to creating integrated and sustainable communities. The explicit inclusion of ICT utilities recognizes modern necessities. Also, the strengthened mandate for family participation and public consultation can lead to more responsive and successful projects.

    For real estate developers, the specific mention of PPPs under Rep. Act No. 11966 (the PPP Code) provides a clearer framework for collaboration, though the incentive landscape has shifted. In addition, real estate developers partnering with NHA could mean incorporating spaces for micro-enterprises or training centers into project designs to ensure the implementation of sustainable livelihood programs for the housing community.

    For residents, it promises not just a home, but an environment conducive to improving their quality of life and economic prospects. The success of this provision will hinge on the NHA’s ability to effectively coordinate with other government agencies and the private sector to deliver these livelihood and community facility components, ensuring they are genuinely responsive to the needs of all their stakeholders.

    ✅ Strategic Asset Management and New Enforcement Powers [Sec. 6.II.d; Sec. 6.IV.d; Sec. 6.IV.f]

    The Act empowers the NHA with new and refined tools for asset management. This includes:

    🛂Establishing a socialized and low-cost housing loan restructuring and condonation program for delinquent but deserving beneficiaries, with clear exclusion criteria.

    🛂The power to summarily eject and dismantle illegal occupants from its properties and resettlement projects, without a judicial order, after proper notice.

    🛂The authority to engage in landbanking by acquiring lands in strategic locations, particularly near transit hubs, for socialized housing development.

    The loan restructuring and condonation program offers a lifeline to beneficiaries facing financial hardship, promoting housing retention. But it has its inherent dangers and may be prone to abuse. Meanwhile, the summary ejectment power is a potent tool for NHA to manage its housing stock and ensure units go to rightful awardees, though its implementation will require careful adherence to due process to protect rights.

    ✅ Formalized and Strengthened Disaster Response [Sec. 13]

    A dedicated Disaster and Emergency Response Housing Office (DERHO) is established under the Authority. This office will formulate and implement plans and programs for families displaced by natural and human-induced disasters, using sustainable, integrated, and community-based approaches in coordination with LGUs, as well as the National Disaster and Risk Reduction and Management Council.

    The creation of DERHO institutionalizes NHA’s role in disaster response housing, moving beyond ad-hoc interventions. This specialized office should lead to more efficient, effective, and timely shelter assistance for calamity victims. For real estate professionals involved in disaster rebuilding or supply chains for emergency shelter, DERHO will likely be a key coordinating body. This also aligns with the narrowed “agency” role for NHA in disposing of lands specifically for calamity victims.

    ✅ Focused Tax Exemptions for NHA’s Direct Operations [Sec. 14]

    The Authority, its assets, properties, and all accruals and income or investment earning therefrom, as well as supplies, equipment and documents, are exempt from any tax, assessment, charge and fee or customs or import duty of any kind, whether imposed by local or national entities (e.g., real property tax, VAT, donor’s tax, and regulatory fees like building permit and ECC fees, etc.)

    More importantly, “[t]he Authority shall be exempt from the payment of documentary stamp tax and registration fees, including fees required for the issuance of transfer certificates of titles”.

    These extensive tax exemptions have the potential to dramatically reduce the cost of socialized housing projects. For real estate developers, this makes partnering with NHA on such projects significantly more attractive, as reduced costs can improve project viability and potentially allow for lower selling prices or improved amenities.

    Clear and unambiguous implementing rules and regulations (IRRs) will be vital. For homebuyers, these savings should ideally translate into more affordable housing units, though the direct extent of pass-through savings will need monitoring.

    ✅ Unlocking Land: Streamlined Acquisition, Conversion, and Management [Sec. 15]

    Under Rep. Act No. 12216, lands identified for housing will be assessed and, if feasible, transferred to the NHA for administration. Critically, “[t]he conversion and reclassification of lands for housing projects shall be without prejudice to the rights of the beneficiaries under Republic Act No. 6657, as amended”. The Authority must also consider access to basic services, transport, and economic opportunities in land selection.

    The “conversion or reclassification” of lands for housing projects is provided, subject to the rights of agrarian reform beneficiaries, and addresses one of the most significant delays in housing production. This provision aims to cut through the bureaucratic red tape associated with land use conversion. However, its implementation will require careful coordination with Local Government Units (LGUs) and their existing Comprehensive Land Use Plans (CLUPs) to avoid conflict and ensure integrated urban development.

    The mandate to select sites with “proximity to economic opportunities” is a welcome directive, preventing the development of isolated communities far from jobs and essential services, a common pitfall in past resettlement projects.

    Finally, this provision of the law is harmonized with the provisions of Rep. Act No. 7279, as amended, also known as the Urban Development and Housing Act of 1992. This decades-old law aims to provide a comprehensive and continuing urban development and housing program. Its primary thrust is to uplift the conditions of underprivileged and homeless citizens by ensuring access to decent housing at affordable costs, along with basic services and employment opportunities.

    Rep. Act No. 7279 or UDHA also promotes the rational use and development of urban land, ensuring equitable utilization of residential areas while optimizing land productivity. It seeks to reduce urban dysfunctions, improve local government capabilities in housing programs, and encourage effective public participation in urban development. Additionally, it establishes a balanced housing development program, requiring developers to allocate a portion of their real estate development projects for socialized housing, ideally.

    We will write about a deeper analysis and other legal implications of the interaction of these two laws – Rep. Act No. 7279, as amended, vis-à-vis Rep. Act No. 12216, in another article in the future.

    ✅ Strengthened Governance and Operational Modernization [Sec. 7 & Sec. 22]

    Under Rep. Act No. 12216, the NHA Board is reconstituted to nine (9) members, chaired by the DHSUD Secretary and including key Department Secretaries, the NHA General Manager, and two (2) expert panel members in housing, urban planning, and development appointed by the President from a GCG shortlist. The inclusion of expert panel members is a significant step towards ensuring technically sound and independent perspectives in NHA’s governance and potentially reducing the politicization of the NHA Board.

    Their “recognized probity and independence” and professional experience should contribute to more technically sound, evidence-based, and innovative housing policies and program designs. This could lead to better quality, more sustainable, and more contextually appropriate housing solutions, benefiting both the industry and the homebuyers.

    Moreover, the Act mandates the NHA to establish and maintain, within one year, operational systems for debt collection, integrated IT and database management (census, lot awards, beneficiary profiling, financial management), and internal controls. The mandate for modernizing operational systems is long overdue and vital for improving efficiency, transparency, data-driven decision-making, and service delivery.

    Finally, for real estate professionals dealing with NHA, these improvements could translate to more streamlined processes and reliable information in the long run. Understanding this new law could mean a more identifiable and streamlined process for proposals involving government land for socialized housing. The speed and transparency with which the NHA and DHSUD, in coordination with LGUs, identify, evaluate, and dispose of these lands will be critical to achieving the intended acceleration of housing development.

    These are the eight (8) pillars that, in our opinion, will propel the NHA to better serve its stakeholders. What do you think will be the major impact of Rep. Act No. 12216 on the socialized and low-cost housing segment of the Philippine real estate industry? Type your comments below and let’s start a conversation.

    ——-

    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 the Ease of Paying Taxes Act Will Revolutionize Real Estate in the Philippines

    “Taxes are the price we pay for a civilized society.”

    – Oliver Wendell Holmes, Jr., Associate Justice of the US Supreme Court

    By Realttorney®

    Let’s face it: taxes have always been the ghost in the room during any property transaction in the Philippines. Whether you’re a developer breaking ground on a new residential enclave, a broker juggling multiple listings, or an heir trying to settle a family estate, tax compliance has often felt like navigating a maze – at times confusing, bureaucratic, and painfully slow.

    But all that may be about to change.

    Last January 2024, Pres. Marcos, Jr. signed into law Republic Act No. 11976, also known as the “Ease of Paying Taxes Act.” It aims to streamline tax administration, making it easier for real estate buyers, sellers, and owners to comply with their obligations. But Rep. Act No. 11976 does not directly address real estate taxation. Instead, it focuses on simplifying the administration of income and estate taxes, which can indirectly impact real estate transactions.

    This article dives into the key features of Rep. Act No. 11976, by highlighting how it benefits various taxpayers and stakeholders in the real estate industry, especially after the BIR released seven (7) Revenue Regulations in the last week of April 2024.

    Streamlined Tax Administration and Tax Compliance:

    One of the most significant benefits of Rep. Act No. 11976 is the emphasis on better and efficient tax administration. To operationalize this, Revenue Regulation No. 8-2024 was issued, which classified taxpayers into four categories:

    1. Micro Taxpayers – those with gross sales of less than P3 million for a taxable year;
    1. Small Taxpayers – those with gross sales of between P3 million to less than P20 million for a taxable year;
    1. Medium Taxpayers – those with gross sales of between P20 million to less than P1 billion for a taxable year; and
    1. Large Taxpayers – those with gross sales of P1 billion and above for a taxable year.

    To be clear, gross sales refer to total sales revenue, net of VAT, if applicable, during the taxable year, without any other deduction. Furthermore, gross sales shall only cover business income, excluding compensation income earned under an employer-employee relationship, passive income under Sections 24[1], 25[2], 27[3] and 28[4], and income excluded under Section 32 (B) of Rep. Act No. 8424, as amended.

    Hence, a mixed income earner (or a person with multiple income streams) will no longer agonize about being unwittingly categorized into a higher classification of taxpayer since the regulation clearly defines gross sales to include only business income.

    However, it should be noted that business income shall include income from the conduct of trade or business or the exercise of a profession. As such, RESPs must know these 4 categories listed above by heart.

    Kindly note that VAT-registered RESPs, business people, and juridical persons shall be automatically classified as Small Taxpayers. But, a taxpayer who will register to engage in business or practice a profession upon the effectivity of RR No. 8-2024 shall initially be classified based on the declaration in the Registration Forms beginning from the year they registered, and shall remain as such unless reclassified.

    Now the concerned taxpayer shall be reclassified in accordance with the threshold values indicated in the 4 items above. Taxpayers shall be duly notified by the BIR of their classification or reclassification, as may be applicable, in a manner or procedure to be prescribed in a revenue issuance to be issued separately.

    Finally, taxpayers registered in 2022 and prior years shall be classified based on their gross sales for the taxable year 2022. But, for taxpayers registered in 2022 and prior years without any submitted information on their gross sales for the taxable year 2022, including taxpayers registered in 2023 or in 2024 before the effectivity of RR No. 8-2024, shall initially be classified as Micro Taxpayer.

    These new classifications of taxpayers were made to encourage tax compliance on the part of all taxpayers in the Philippines.

    Streamlined Tax Filing and Payment

    The Act encourages the BIR to develop user-friendly online platforms for filing tax returns and paying taxes. This translates to:

    • Reduced Time and Cost: Imagine the convenience of filing tax returns electronically from the comfort of your office or home. This eliminates the need to travel to BIR offices and stand in queues, saving valuable time and resources. No more going to and queuing at Authorized Agent Banks (AABs) of different Revenue District Offices (RDOs) all over the country.
    • Fewer Errors: Online filing systems often come with built-in validation checks, minimizing the risk of errors in tax computations and filings.

    Improved Taxpayer Assistance by Modernizing the BIR Systems

    The Act emphasizes providing better taxpayer assistance. The BIR is mandated to perform the following:

    • Enhance taxpayer education: This could involve providing clear and accessible information on tax obligations specific to real estate transactions, such as capital gains tax for property sales or documentary stamp taxes, among others.
    • Establish a more responsive taxpayer hotline: A dedicated and accessible hotline can address taxpayer queries promptly, reducing confusion and frustration. It’s been more than one year since the law became effective. I am not so sure if the BIR has indeed established a more responsive hotline for taxpayers.

    Potential for Reduced Penalties and Interest

    The Act emphasizes fair treatment of taxpayers. While it doesn’t directly waive penalties and interest on late tax payments, it lays the groundwork for a more efficient system. With easier filing and clearer communication, the likelihood of unintentional tax delinquency might decrease. Additionally, the BIR may be more lenient with taxpayers who demonstrate a genuine effort to comply.

    All these reforms are not just superficial changes. It is a change in philosophy. The government is finally recognizing that one size does not fit all, especially in an industry as complex and as vital as real estate.

    Quid Nunc?

    So, what does this mean for you? Whether you own a condominium unit in BGC, manage real estate investments from overseas, or make your living closing deals and filing tax returns, here’s why Rep. Act No. 11976 matters – and how it might just be the best thing to happen to Philippine real estate in years.

    For Real Estate Developers: A Breath of Fresh Air

    If you’ve ever worked behind the scenes of a property development, you know that taxes can make or break project timelines. Filing monthly VAT returns, waiting endlessly for VAT refunds, if any are forthcoming, and managing the ever-changing interpretations of “business style” in official receipts have long been thorns in the side of real estate developers.

    Rep. Act No. 11976 changes the game by allowing developers (and real estate professionals) to:

    • File VAT returns quarterly instead of monthly—a huge administrative relief.
    • Get VAT refunds faster, thanks to a digitalized and standardized process.
    • Forget about “business style” descriptions on receipts, eliminating confusion and clerical inconsistencies.

    For Property Buyers and Property Owners: More Confidence, Less Complexity

    Buyers of real estate will benefit from the reduced transaction time under this relatively new law. The faster processing of the payment of the appropriate tax filing expedites the issuance of certificates authorizing registration and tax clearances, which is a very crucial document for real estate transactions. This can lead to quicker property transfers.

    Property owners – especially those selling land or receiving inherited properties – have traditionally relied on lawyers or licensed real estate brokers to help navigate the tax minefield. But this new law provides some much-needed breathing room.

    Here’s how:

    • Simplified Tax Compliance: The streamlined filing process can save property owners (sellers or heirs) valuable time and resources during property sales.
    • Reduced Compliance Burden: Clearer communication from the BIR can help sellers avoid unintentional tax errors and potential penalties.

    Imagine this: an 82-year-old widow in Quezon City, working to settle her late husband’s estate, no longer needs to deal with stacks of paper forms or wait in endless queues. With the help of a CPA or estate planner using accredited tax systems, her tax filings are secure and timely.

    Real Estate Owners (Landlords and Landladies): Stress-free Management

    • Easier Rental Income Reporting: Online filing systems can simplify the process of reporting rental income and paying income taxes.
    • Improved Access to Tax Information: Clearer and more accessible information from the BIR can help property owners understand their tax obligations related to rental income and property ownership.

    For OFWs and Foreign Investors: No More Flying Home Just to Pay Taxes

    If you’re a Filipino-American, an overseas worker, or a foreign investor who owns land or property in the Philippines, this law is music to your ears. Why? It should be emphasized that all taxes can now be filed and paid online. You have direct control over how you pay and when to pay your taxes.

    Better still, the BIR now recognizes tax service providers who can file the appropriate returns on your behalf, and these filings are considered official.

    That means you don’t need to fly back just to settle capital gains tax or sign estate tax documents. A well-trusted tax lawyer or CPA can now take care of this with full legal effect. With real-time access to filings and BIR receipts, managing a Philippine property portfolio abroad just became more viable.

    For Brokers and Real Estate Professionals: Clarity and Control

    Real estate brokers, listen up. This law could be one of the best tools you didn’t know you needed. Why?

    Historically, brokers have struggled with unclear tax obligations. Are you subject to VAT or percentage tax? Are you filing too much, too often? Worse, issuing a receipt with a mismatched “business style” could trigger an audit.

    What’s better now:

    • The law removes the need to state “business style”, which often caused mismatches between BIR records and what’s written on paper.
    • It clearly classifies taxpayers into micro, small, medium, and large, so brokers with modest earnings aren’t lumped into the same compliance group as corporations.
    • Online filing is now standard, making it easier to comply, even if you live or work in provinces where tax offices are limited.

    Let’s not forget the countless real estate brokers in the past who were penalized for minor infractions in receipts or due to confusion in VAT versus percentage tax requirements. Those days are long gone.

    What to Watch Out For: Implementation Hiccups

    While Rep. Act No. 11976 holds promise for a more taxpayer-friendly environment, its full impact will depend on the BIR’s implementation. Let’s not pretend this will be perfect after more than a year since the effectivity of this law. There are still challenges. And the success of the Act hinges on several factors.

    First, the BIR’s digital infrastructure must catch up quickly. User-friendly online platforms for filing and payment are crucial for achieving the intended benefits. Nationwide implementation requires investment and training for all BIR personnel.

    Second, many tax professionals and real estate service practitioners need retraining to adapt to new systems and classifications.

    Third, aside from professionals, educating taxpayers about their obligations and the new system is vital for ensuring smooth adoption.

    So, while the law is promising, vigilance is still the name of the game. So here are some practical advice for real estate stakeholders – whether you’re a developer, RESP, investor, or heir, here’s what you can do today to benefit from this landmark law:

    1. Review your tax filings and registration. Know what category you fall under.
    1. Update your invoice and receipt formats. Remove “business style” fields and comply with new standards.
    1. Go digital. Sign up for BIR’s eFPS and consult with accredited service providers.
    1. Ask for help. Engage a lawyer-CPA who understands both tax law and real estate. It’s worth it.

    In Closing: A Quiet Revolution for a Complex Industry

    The Ease of Paying Taxes Act isn’t just about cutting red tape. It’s about trust in a system that no longer sees taxpayers as adversaries, but as partners. And in the world of real estate, where fortunes rise and fall on timing, transparency, and compliance, this law may just be the quiet revolution we’ve been waiting for.

    So, the next time you close a sale, inherit a parcel of land, or get ready to invest in property, take comfort in knowing that the system behind the scenes is finally catching up with you, and for you.

    Rep. Act No. 11976 is not just a law. It’s a signal that things in Philippine real estate are about to get a lot easier – and a whole lot smarter. The law represents a positive step towards simplifying tax compliance in the Philippines.

    If you are a real estate service professional, you can play a vital role in disseminating information about the Act’s benefits to your clients. By understanding these changes, real estate buyers, sellers, and owners can navigate the tax landscape with greater ease and confidence. Remember, consulting with a tax advisor is always recommended for specific tax situations related to real estate transactions.

    Share your thoughts by leaving your comments in the comments section, and let’s start a conversation.

    ——-

    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.

    [1] On Interests, Royalties, Prizes, and Other Winnings, and Cash and/or Property Dividends of Individual Citizens.

    [2] On Prizes amounting to PhP 10,000.00 or less; and royalties on books as well as other literary works, and royalties on musical compositions of an Individual Resident Alien.

    [3] On Interest from Deposits and Yield or any other Monetary Benefit from Deposit Substitutes and from Trust Funds and Similar Arrangements, and Royalties; and Tax on Income Derived under the Expanded Foreign Currency Deposit System of Domestic Corporations.

    [4] Tax on Resident and Non-Resident Foreign Corporations.

  • Legal Insights on Real Estate in Corporate Liquidation

    “Besides a happy policy as to civil government, it is necessary to institute a system of law and jurisprudence founded in justice, equity and public right.”

    – Ezra Stiles, American Education & Theologian

    (Part 3 of 4)

    By Realttorney®

    In the previous article, we covered the background and step-by-step procedures for selling real estate registered in the name of a dissolved corporation. We now turn to discussing several key jurisprudences. The Supreme Court has issued multiple rulings that clarify the extent of a “dead” corporation’s authority and the validity of its transactions post-dissolution.

    These decisions are binding legal precedents and valuable guidance for real estate service professionals.

    ⚖️ Rich v. Paloma III (G.R. No. 210538, March 7, 2018)

    📚 Facts Leading to the Controversy:

    📌 In 1997, Dr. Gil Rich lent ₱1,000,000 to his brother, Estanislao Rich, secured by a real estate mortgage over a 1,000-square-meter parcel of land in Maasin City, Southern Leyte.

    📌 When Estanislao failed to pay, Dr. Rich foreclosed on the property in March 2005 and was declared the highest bidder at the auction.

    📌 Unknown to Dr. Rich, Estanislao had previously mortgaged the same property to Maasin Traders Lending Corporation (MTLC) in January 2005 for ₱2.6 million.

    📌 MTLC, through its president, Ester Servacio, redeemed the property in March 2006, despite being dissolved by the Securities and Exchange Commission in September 2003.

    🌐 Main Issue to be Resolved: Was MTLC legally capable of redeeming the property despite its dissolution?

    💡 Key Legal Principles Applied

    ✅ Corporate Dissolution & Liquidation: The Supreme Court ruled that a dissolved corporation retains no juridical personality except for liquidation purposes. Since MTLC had ceased to exist before the mortgage agreement, it could not validly redeem the property.

    ✅ The Supreme Court reversed the Court of Appeals’ decision and declared the real estate mortgage between Estanislao and MTLC null and void. It also ordered the cancellation of the Deed of Redemption in favor of MTLC.

    ⚖️ Yu v. Yukayguan (G.R. No. 177549, June 18, 2009)

    📚 Facts Leading to the Controversy:

    📌 The case involved a dispute between Anthony S. Yu and Joseph S. Yukayguan, who were half-brothers and stockholders of Winchester Industrial Supply, Inc. (Winchester, Inc.).

    📌 Joseph and his family filed a derivative suit against Anthony and his family, alleging embezzlement, falsification of corporate records, and misappropriation of corporate funds.

    📌 The Regional Trial Court (RTC) of Cebu City dismissed the complaint, ruling that the plaintiffs failed to meet the requirements for a derivative suit.

    🌐 Main Issues to be Resolved: (1) Did the plaintiffs properly exhaust all remedies before filing the derivative suit, and (2) Should the case be remanded for further proceedings given the dissolution of Winchester, Inc.

    💡 Key Legal Principles Applied

    ✅ Requirements for a Derivative Suit: The Supreme Court emphasized that a stockholder must exhaust all available remedies within the corporation before filing a derivative suit. The plaintiffs failed to prove they had done so.

    ✅ Corporate Dissolution & Liquidation: Since Winchester, Inc. had been formally dissolved, the Court of Appeals remanded the case to the RTC to oversee the final settlement of corporate assets.

    ✅ In the end, the Supreme Court affirmed the RTC’s dismissal of the derivative suit but upheld the remand of the case to the RTC for the proper distribution of corporate assets following the dissolution of Winchester, Inc.

    ⚖️ Aguirre v. FQB+7 (G.R. No. 170770, Jan. 9, 2013)

    📚 Facts Leading to the Controversy:

    📌 FQB+7, Inc. was a corporation established in 1985, with its original board of directors and stockholders listed in its Articles of Incorporation.

    📌 In 2002, a General Information Sheet (GIS) was filed with the Securities and Exchange Commission (SEC), reflecting changes in the corporation’s directors and stockholders, including the heirs of a deceased stockholder.

    📌 Vitaliano Aguirre II, a stockholder, discovered the GIS in 2004 and questioned its validity, alleging that the changes were fraudulent and unauthorized.

    📌 Thereafter, Aguirre filed a complaint for intra-corporate dispute, seeking an injunction, inspection of corporate books, and damages.

    🌐 Main Issues to be Resolved: (1) Did the trial court have jurisdiction over the intra-corporate dispute despite the corporation’s dissolution, and (2) Was the GIS valid, and did the respondents have the authority to act as corporate officers?

    💡 Key Legal Principles Applied

    ✅ Jurisdiction Over Intra-Corporate Disputes: The Supreme Court ruled that corporate dissolution does not automatically terminate intra-corporate disputes. Under Section 145 of the old Corporation Code, rights and remedies of stockholders and directors remain enforceable even after dissolution.

    ✅ Corporate Liquidation: A dissolved corporation retains limited juridical personality for the purpose of winding up its affairs, including resolving disputes over stock ownership and corporate governance.

    ✅ Validity of Corporate Acts: The Court emphasized that corporate records, such as GIS filings, must be properly authenticated and that unauthorized changes to corporate governance can be challenged.

    ✅ The Supreme Court partially granted the petition, reinstating the intra-corporate case before the trial court while nullifying the writ of preliminary injunction. It clarified that the dispute should proceed to determine the rightful corporate officers and stockholders.

    ⚖️ Gelano v. Court of Appeals (G.R. No. L-39050, Feb. 24, 1981)

    📚 Facts Leading to the Controversy:

    📌 Insular Sawmill, Inc., a corporation engaged in the lumber business, leased a property owned by Guillermina Mendoza de Gelano in Manila.

    📌 Guillermina’s husband, Carlos Gelano, obtained cash advances from Insular Sawmill amounting to ₱25,950, agreeing that the corporation could deduct the amount from rental payments.

    📌 Carlos failed to fully repay the advances, leaving an unpaid balance of ₱20,000.

    📌 Additionally, the couple made credit purchases of lumber materials worth ₱946.46 for home improvements, which remained unpaid.

    📌 Insular Sawmill also co-signed a promissory note with Carlos for a ₱8,000 loan from China Banking Corporation, which Carlos failed to settle, leaving a balance of ₱4,106.

    📌 Guillermina refused liability, arguing that the debts were personal obligations of her husband.

    🌐 Main Issue to be Resolved: Could Insular Sawmill, Inc. continue prosecuting the case despite its corporate dissolution?

    💡 Key Legal Principles Applied

    ✅ Corporate Dissolution & Litigation: The Supreme Court ruled that a dissolved corporation may continue prosecuting pending cases beyond the three-year winding-up period, provided there is substantial compliance with liquidation procedures.

    ✅ Trustee Representation: Even without a formal trustee, the corporation’s legal counsel was deemed to have substantially fulfilled the role of a trustee for litigation purposes.

    ⚖️ Clemente v. Court of Appeals (G.R. No. 82407, Mar. 27, 1995)

    📚 Facts Leading to the Controversy:

    📌 The case involved a dispute over ownership of a 5,349-square-meter parcel of land in Calamba, Laguna.

    📌 The land was originally acquired by Sociedad Popular Calambeña, an organization that operated as a sociedad anónima (anonymous partnership) from 1909 to 1932.

    📌 The petitioners, including Luis C. Clemente, claimed ownership based on their stockholdings in the dissolved entity.

    📌 The respondents, Elvira Pandinco-Castro and Victor Castro asserted ownership through acquisitive prescription, arguing that they had possessed the land openly and continuously.

    🌐 Main Issues Resolved: (1) Did the petitioners have a valid claim to ownership based on their stockholdings in Sociedad Popular Calambeña, and (2) Could the respondents acquire ownership through acquisitive prescription despite the petitioners’ claims?

    💡 Key Legal Principles Applied

    ✅ Ownership Rights of Dissolved Entities: The Supreme Court ruled that stockholders of a dissolved corporation do not automatically acquire ownership of corporate assets unless proper liquidation procedures are followed.

    ✅ Acquisitive Prescription: The Court upheld the principle that continuous, open, and adverse possession of property for the required period can lead to ownership, provided there is no legal impediment to prescription.

    ✅ Burden of Proof in Ownership Claims: The petitioners failed to establish a clear legal basis for their claim, as they did not present sufficient evidence proving their direct ownership of the land.

    ✅ Hence, the Supreme Court affirmed the Court of Appeals’ decision, rejecting the petitioners’ claim and recognizing the respondents’ ownership through acquisitive prescription.

    ⚖️ Reburiano v. Court of Appeals (G.R. No. 102965, January 21, 1999)

    📚 Facts Leading to the Controversy:

    📌 Pepsi Cola Bottling Company of the Philippines, Inc. filed a case against Urbano Reburiano and James Reburiano for unpaid obligations amounting to ₱55,000.

    📌 The Regional Trial Court (RTC) of Quezon City ruled in favor of Pepsi, ordering the defendants to pay the amount, with deductions for returned empty cases.

    📌 Pepsi appealed to the Court of Appeals, which modified the RTC’s ruling, ordering the defendants to pay ₱55,000 with legal interest from January 1982.

    📌 After the case became final and executory, the RTC issued a writ of execution in 1991.

    📌 The Reburianos moved to quash the writ, arguing that Pepsi had ceased to exist as a corporation in 1983, thus losing its juridical personality to sue or enforce judgments.

    🌐 Main Issues Resolved: Could Pepsi Cola Bottling Company enforce the judgment despite its corporate dissolution?

    💡 Key Legal Principles Applied

    ✅ Corporate Dissolution & Liquidation: The Supreme Court ruled that a dissolved corporation retains limited juridical personality for three years to settle affairs and prosecute pending cases.

    ✅ Trustee Representation: Even without a formal trustee, the corporation’s legal counsel was deemed to have substantially fulfilled the role of a trustee for litigation purposes.

    ✅ Finality of Judgments: The Court emphasized that final and executory judgments must be enforced, and procedural objections raised after finality cannot prevent execution.

    ✅ The Supreme Court affirmed the Court of Appeals’ decision, ruling that Pepsi Cola Bottling Company could still enforce the judgment despite its dissolution. The motion to quash was denied, and the execution of the judgment was upheld.

    ⚖️ Alhambra Cigar & Cigarette Manufacturing Company, Inc., vs. SEC (G.R. No. L-23606, July 29, 1968)

    📚 Facts Leading to the Controversy:

    📌 Alhambra Cigar & Cigarette Manufacturing Company, Inc. was incorporated in 1912 with a corporate term of 50 years, set to expire on January 15, 1962.

    📌 Upon expiration, Alhambra ceased operations and entered liquidation, appointing Angel S. Gamboa as trustee.

    📌 In 1963, Republic Act No. 3531 was enacted, allowing corporations to extend their corporate life beyond the original term.

    📌 Alhambra attempted to amend its Articles of Incorporation to extend its corporate existence for another 50 years.

    📌 The Securities and Exchange Commission (SEC) rejected the amendment, ruling that Republic Act No. 3531 had no retroactive effect and could not apply to corporations whose term had already expired.

    🌐 Main Issues Resolved: Could Alhambra extend its corporate life after its original term had expired?

    💡 Key Legal Principles Applied

    ✅ Corporate Life Extension: The Supreme Court ruled that a corporation cannot extend its existence once its original term has expired. Any amendment must be made before expiration.

    ✅ Non-Retroactivity of Laws: Republic Act No. 3531 did not apply retroactively, meaning corporations that had already ceased to exist could not revive themselves through an amendment.

    ✅ SEC’s Authority: The Court upheld the SEC’s decision, affirming its authority to reject amendments that violate corporate law principles.

    ✅ The Supreme Court affirmed the SEC’s decision, ruling that Alhambra could not extend its corporate life after expiration. The corporation remained in liquidation, and its assets were to be distributed accordingly.

    These are some of the decisions promulgated by the Supreme Court that will guide practitioners to understand the process of dissolution and the underlying legal principles behind it. May this review of related jurisprudence be a valuable tool for all practitioners alike.

    Now, real estate service practitioners play a vital role in safeguarding the legality and integrity of property transactions involving dissolved corporations. Whether the sale is conducted during or after the 3-year liquidation window, it is essential to:

    👉 Identify the correct person or group of persons who is/are authorized to sell the property.

    👉 Conduct proper and exhaustive legal due diligence on the entity and the property subject to the purchase.

    👉 Ensure full legal transparency to protect all parties to the transaction.

    When in doubt, consult a corporate or real estate lawyer familiar with liquidation and estate laws. Ethical practice and legal compliance should always be aligned.

    The last part of the series will discuss the path to resurrecting a “dead” corporation in light of the enactment of the Revised Corporation Code (Rep. Act No. 11232).

    ——-

    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.

  • Guide to Owning Property in the Philippines as a NRF or Dual Citizen

    The law of property determines who owns something, but the market determines how it will be used.”

    – Ronald Coase, British Economist & Noble Laureate

    By Realttorney®
     
    If you’re a Filipino-American, a dual citizen, or a non-resident Filipino (NRF), owning property in the Philippines might feel like coming home – literally and emotionally. But as with anything involving real estate and international ownership, you’ve got to understand the legal and tax rules that come with the territory.
     
    First of all, let’s define: Who is a Non-Resident Filipino or Dual Citizen? Understanding your legal identity is the first crucial step in the process of desiring to buy real estate in the Philippines.
     
    ✅ Dual Citizen
     
    How do you become a dual citizen? Rep. Act No. 9225, known as the “Citizenship Retention and Re-acquisition Act of 2003,” allows natural-born Filipino citizens who have lost their Philippine citizenship because of their naturalization as citizens of a foreign country to be deemed to have re-acquired Philippine citizenship upon taking the oath of allegiance to the Republic specified in the said law.
     
    👉 So, if you are a former natural-born Filipino who has already re-acquired Philippine citizenship, then you retain your U.S. citizenship. As such, in the eyes of the law, you’re now 100% Filipino with all the rights and responsibilities of any other citizen, including ownership of real estate without restrictions.
     
    ✅ Non-Resident Filipino (NRF)
     
    This group includes (1) OFWs; (2) Filipino immigrants who retained Philippine citizenship; and (3) Filipino citizens who live abroad for long periods (but haven’t renounced their citizenship).
     
    👉 The key for this group is that as long as you retain Philippine citizenship, you’re allowed to own land, condominium units, house and lot, and townhouses, etc. – even if you live abroad.
     
    ✅ Former Filipinos
     
    As a side note, former natural-born Filipinos who do not wish to apply for dual citizenship or are not qualified to re-acquire Filipino citizenship according to Rep. Act No. 9225 may still acquire land under the provisions of Batas Pambansa Bilang 185.
     
    Under this law, former natural-born Filipinos can be a transferee of a private land up to one thousand (1,000) square meters, in the case of urban land. But, a former natural-born Filipino may be a transferee of a private land up to an area of one (1) hectare in the case of rural land. The final restriction here is that the private land to be purchased (whether urban or rural land) should be used by the transferee as his residence and not for business purposes.
     
    🏠 What Are Your Property Ownership Rights?
     
    Here’s the good news: if you’re a dual citizen or an NRF, you enjoy full rights to own real estate in the Philippines.
     
    You can legally acquire:
    ✅ Residential lots
    ✅ House-and-lot properties
    ✅ Condominiums
    ✅ Agricultural land
    ✅ Commercial property (with necessary business permits from the LGU)
     
    Just like any Filipino citizen, you can:
     ✅ Buy, sell, or inherit real estate
    ✅ Transfer property to heirs or family
    ✅ Register the title in your name
    ✅ Use the property as rental income, a vacation home, or a retirement residence
     
    📌 Reminder: Foreigners are prohibited from owning land. They may only own condo units or lease land for the long term. Read here if you want to learn more about this topic.
     
    ⚖️ Legal Considerations for Overseas Buyers
     
    Here are some legal factors you must stay on top of as an overseas property owner:
     
    1. Special Power of Attorney (SPA)
     
    Since you’re not physically present in the Philippines, any legal transactions (e.g., signing contracts, submitting documents, paying taxes) will require an SPA authorizing someone in the Philippines to act on your behalf.
     
    ✔️ The SPA must be notarized by the Philippine Consulate in your country.
    ✔️ It should specify exact powers (e.g., to sign, sell, lease, or mortgage property).
    ✔️ Submit this SPA to the Register of Deeds and BIR for proper recognition.
     
    2. Title Registration
     
    Make sure that:
    ✔️ The property is titled under your legal name, and it matches your government ID or Philippine passport.
    ✔️ If the property is inherited or gifted, go through the legal process of estate settlement and register the transfer accordingly.
     
    ⚠️Don’t leave land titles under the names of deceased relatives or informal agreements. This can lead to legal disputes or costly litigation later on.
     
    3. Zoning and Land Use
     
    Some land types (e.g., agricultural, residential, or commercial) have restrictions on what you can build or do with the property.

    ✔️ You may need a conversion certificate if you plan to create a farm tourism business.
    ✔️ Check with the LGU (Local Government Unit) for zoning laws, building permits, and usage rules.
     
    💸 Tax Implications for Dual Citizens and Non-Resident Filipinos
     
    Now, let’s talk about everyone’s favorite topic: taxes. As a property owner in the Philippines, even if you live abroad, you’re still liable for certain taxes.
     
    📌 1. Real Property Tax (RPT)
    ✅Paid annually to the LGU.
    ✅Based on the assessed value of your property.
    ✅Ranges between 1%–2% depending on the classification and assessment level of the property.
     
    💡 Pay before January 31 each year to avoid penalties. Or better yet, you can pay the RPT in advance and get a twenty percent (20%) discount for the incoming full year’s RPT. You can assign this task to a representative in the Philippines.
     
    📌 2. Capital Gains Tax (CGT)
    ✅Applicable when you sell a property, whether you incur an actual gain or not.
    ✅The rate is 6% of the gross selling price or the current schedule of market value (whichever is higher).
    ✅Paid by the seller (but often negotiated).
     
    📍Even if you’re a non-resident, you must file and pay CGT through the Bureau of Internal Revenue (BIR) before title transfer.
     
    📌 3. Documentary Stamp Tax (DST)
    ✅Paid by the buyer at a rate of 1.5%.
    ✅Applies when executing a Deed of Absolute Sale, Donation, or Mortgage Agreement, among other documents.
     
    📌 4. Donor’s Tax
    ✅Applicable when gifting property to another person.
    ✅Taxed at 6% of the current schedule of market value of the donated property.
    ✅Exemptions apply for gifts up to P250,000 in value, annually.
     
    📌 5. Estate Tax
    When the owner passes away, the heirs must pay estate tax before they can legally transfer ownership.
    ✅Rate: 6% of the net estate (after deductions).
    ✅Heirs must file within 1 year from the date of death.
     
    ✔️ Pro Tip: Create an Estate Plan if you own real property here in the Philippines. It will make estate settlement easier for your immediate family later on.
     
    🌐 Do You Need to File Income Taxes in the Philippines?
     
    It depends on whether your property is income-generating.
     
    ✔️ If You Lease or Rent Out Your Property:
    ✅You are considered to be earning income in the Philippines.
    ✅You must register with the BIR and pay:
    ✅Income tax (depending on rental income)
    ✅Value-added tax (VAT) or percentage tax, if applicable
     
    You may hire a Philippine accountant to help you file the necessary returns annually. Failure to register and pay taxes can result in penalties.
     
    ❌ If You Do Not Earn Any Philippine-Sourced Income:
     
    You are not required to file income taxes in the Philippines. But you’re still responsible for property taxes, and you must properly report any sale or transfer of property.
     
    💼 Can You Open a Bank Account or Get a Loan as a Dual Citizen?
     
    Yes. In fact, most banks in the Philippines allow dual citizens and non-resident Filipinos to:
    ✅ Open peso or dollar accounts
    ✅ Apply for housing loans, auto loans, and even investment loans
     
    However, most banks will require:
    ✅ Proof of income (COE or payslips)
    ✅ TIN and government-issued ID
    ✅ Dual citizenship certificate (if applicable)
     
    Some banks have special programs tailored for OFWs and overseas buyers — check out BDO, BPI, Security Bank, or RCBC for their “home loan for foreigners or overseas Filipinos” programs.
     
    ✈️ Key Takeaways
     
    Owning property in the Philippines as a non-resident or dual citizen isn’t just a dream — it’s a well-supported legal right. But to make it stress-free and financially sound, you need to:
     
    ✅ Know your rights under Philippine laws
    ✅ Register everything properly with the Registry of Deeds and BIR
    ✅ Keep up with annual tax obligations
    ✅ Avoid common legal mistakes by hiring licensed professionals
     
    And always — always — leave a clear paper trail for your heirs or representatives, especially if your property is meant to be passed on.
     
    📚 BONUS: Quick Checklist
     
    Here’s your quick reference guide:
     
    ✅ Dual citizenship certificate or proof of Filipino citizenship
    ✅ Valid Philippine Tax Identification Number (TIN)
    ✅ Annual RPT payment receipt
    ✅ SPA (if managing from abroad)
    ✅ Legal ownership documents (TCT/CCT, tax dec, etc.)
    ✅ Draft or notarized Philippine will (if applicable)
    ✅ Hire a PRC-licensed real estate broker and a real estate attorney
    ✅ Consult a CPA, if earning rental income
     
    📞 Need Help with Your Property Taxes or Legal Setup?
     
    If you’re based in the U.S. and need help:
     
    ✅Filing your Philippine taxes
    ✅Drafting a Special Power of Attorney
    ✅Reviewing a Deed of Sale or Title
    ✅Creating an estate plan for your properties – real and personal – in the Philippines
     
    📩 Reach out to a licensed Philippine real estate lawyer or estate planning expert who specializes in overseas Filipino clients.
     
    ——-
     
    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.
     

  • Step-by-Step Guide to Selling Real Estate Owned by a “Dead” Corporation

    “We should all be obliged to appear before a board every 5 years and justify our existence… on the pain of liquidation.”

    – George Bernard Shaw, Irish Playwright and Political Activist

    (Part 2 of 4)

    By Realttorney®

    In Part 1 of this series, we discussed how corporations in the Philippines may be dissolved and how their legal personality is extended for a limited period to allow for liquidation. We now turn to the practical steps for selling real estate still registered in the name of a corporation that has lost its corporate franchise, commonly referred to as a “dead” corporation.

    Depending on whether the sale occurs within or beyond the three-year winding-up period provided by law, the procedure varies. Licensed real estate brokers, lawyers, and buyers alike need to know which rules apply.

    Scenario A: Sale Within the 3-Year Liquidation Period

    If the corporation is dissolved but the three-year liquidation period under Section 139 of the Revised Corporation Code has not yet expired, the corporation retains limited legal capacity to dispose of its property.

    Here are the procedural steps:

    1. Confirm the Dissolution Status. Obtain a Certificate of Dissolution from the Securities and Exchange Commission (SEC). Then, verify the effective date of dissolution and compute the expiration of the 3-year window.

    2. Review the Articles of Dissolution. Check if liquidators or trustees have been designated. If not, the board of directors may continue to act for liquidation purposes as long as it is within the 3-year period.

    3. Secure Corporate Authority to Sell. A board resolution must be issued by the board of liquidators or remaining directors, authorizing the sale of the specific property.

    4. Conduct Legal Due Diligence. Verify that the Torrens title is clean and under the corporation’s name. Thereafter, check the tax declaration, ensure that real estate taxes are current, and identify any liens or encumbrances, if any.

    5. Execute the Deed of Sale. The corporation, represented by its liquidator, signs the Deed of Absolute Sale. It is important to emphasize that the buyer must be informed that the seller is a dissolved corporation acting only within its winding-up capacity.

    6. Comply with BIR Requirements. Pay Capital Gains Tax (CGT), Documentary Stamp Tax (DST), and Value-Added Tax (VAT) if applicable. After a few weeks, kindly secure the Certificate Authorizing Registration (CAR) from the Bureau of Internal Revenue (BIR). This is one requirement for the payment of transfer tax at the Local Treasurer’s Office.

    7. Register the Sale. Submit the Deed (or transferring document), the CAR, and other required documents to the Registry of Deeds. Pay the registration fees and process the cancellation and issuance of the new title.

    Scenario B: Sale After the 3-Year Liquidation Period

    Once the three-year period lapses, the corporation loses its capacity to act, including the authority to sell property. However, the law provides remedies through trusteeship or court-supervised liquidation.

    1. Check for Trust Assignment. Determine whether the corporation executed a trust assignment of its assets to named trustees before the 3-year period ended. If so, the trustees now have the authority to sell the property.

    2. If No Trustees Were Appointed. Under some jurisprudence, the assets of the corporation are held in trust for the benefit of stockholders. This means that the stockholders now own the property pro indiviso (undivided) and must act collectively.

    3. Initiate SEC or Court Action if Necessary. If disputes arise, the parties may petition the SEC or a Regional Trial Court to appoint a liquidator or approve a partition. This is common when there are missing or uncooperative shareholders.

    4. Execute the Sale Through Trustees or Stockholders. On the first hand, the trustees may execute the sale through a Trust Deed. On the other hand, if stockholders are selling the property themselves, they must first agree on and execute a partition, either judicially or extrajudicially.

    5. Process BIR and Title Transfer. The sale is subject to standard tax compliance (payment of CGT, DST, VAT, etc.). Kindly note that title transfer may require proof of succession or trust assignment, along with updated corporate or stockholder documentation.

    Risk Management and Ethical Considerations

    Practitioners should be mindful of the following risks:

    1. The absence of designated liquidators may delay transactions.

    2. Simulated sales or transactions without proper authority may be void.

    3. Buyers must be fully informed of the dissolved status of the selling entity.

    4. Brokers may face administrative or civil liability if they facilitate a legally defective transaction.

    In conclusion, even a “dead” corporation can sell its real estate under Philippine law, but only under certain conditions and within certain timeframes. Whether within or beyond the 3-year liquidation period, strict compliance with legal procedures, BIR rules, and SEC documentation is essential.

    In the third part of this series, we will examine key Supreme Court decisions that provide insight into the legal treatment of corporate liquidation and property disposition.

    ——-

    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.