My Estate Of Mind

Case Study: The Barack Obama Strategy

2010-07-16T08:44:00.001-07:00

In this slideshow, you will be shown a presentation on how social media, the internet and other digital tools helped elect US President Barrack Obama to power.

Case Study: The Barack Obama Strategy

View more presentations from SocialMedia8 Amsterdam.

The Social Network aka Facebook The Movie: Watch The Trailer Here

2010-06-26T12:31:00.000-07:00

In the 1990s, it was Sandra Bullock running away from falling dead bodies while trying to regain back her identity in the movie The Net.

More than 10 years later (after the dot com crash and the rise of Google)comes - The Social Network also known as Facebook the movie is set for release anytime this year (or maybe early next year).

Watch the teaser trailer here:

(video from Mashable.com)

According Mashable.com's latest update:

"The Social Network, otherwise known as “the Facebook (Facebook) movie,” is based in part on the book The Accidental Billionaires. It chronicles the formative days of Facebook, from its founding in Mark Zuckerberg’s Harvard dorm room through its early rise to success. Written by Aaron Sorkin and directed by David Fincher, the film stars Jesse Eisenberg as Zuckerberg. It hits theaters this October.

The tag line for the film, “You can’t make 500 million friends without making a few enemies” seems to sum up some of those early days, and the film (or at least the version of the script that I read) is as much an exploration of young people coming to terms with creating something bigger than themselves as much as it is about loyalty, jealousy and money." (check the entire article here: http://mashable.com/2010/06/25/social-network-teaser-trailer/)

Well, sounds like an intriguing-tech-rock star story to me. Of course, I will reserve all comments on the movie until I see it but so far, nothing else could create quite a buzz in Facebook than -- well, Facebook.

iPhone 4 Antenna Pisses Off Hitler

2010-06-25T20:35:00.000-07:00

The iPhone 4 has been creating a lot of buzz lately among technophiles and many excited consumers. However, one famous (or infamous) user has been quite open with his dislike for the new phone.

In this video, let the Fuhrer himself, Hitler show you what he thinks of Apple's latest iPhone release. This is another parody of that excellent film, The Downfall (which has spawned a whole truck load of spoofs ranging from the financial crises to Paris Hilton). Film credits go to Michael Ingram Jr. as posted in Techcrunch.com.

Enjoy!

He's Upset About the iPhone 4 Antenna from MG Siegler on Vimeo.

Why Should Only The Big Boys (Business) Have All The Fun?

2010-06-10T06:52:00.000-07:00

If you're just starting your business or already running or managing a new company, you have probably often feel like David facing not just one probably dozens Goliaths eagerly waiting to swallow up any new upstarts.

Sure, you may have prepared well for this encounter:

- You have a killer product or service
- You have done you research & homework
- You identified the right market who seems very positive to receive your product
- You have the guts, passion and discipline to reach your goal

But you & I know, in business...it's never going to be a walk in the park
Your competitors are ready to take on you & your company to the cleaners.

They have more manpower, firepower & resources than you.

So how do you rise up to the challenge? Why should your competitors have all the fun?

Like our biblical hero David, you need a silent but powerful partner such as the 1 Business System.

1 Business levels the playing field between you and your competitors. It incorporates all the vital elements you need to establish a full online business without costly disparate tools, a large & expensive staff & long learning curve.

1 Business is a quick, easy & reliable way for you to:

* Build a powerful business website
* Sell Anything Online, from physical products to downloads
* Generate More Sales
* Automates Your Recording, Tracking & Extraction Detailed Information On Your Customers
* Communicate & Build Your Brand Image and many more...

All these without needing to learn programming or web coding.

1 Business is designed to take care of the technology side of your business so that you can focus on what you do best: growing your business.

Most of your competitors probably had a head start & accumulated a lot resources & networks than you
They have an army of staff, sales people with structured departments, lots of cash & an extensive network of contacts.

Their size & budgets alone can be intimidating.

Since your competitor's staff handle tasks such as customer relations, sales & marketing, they have more time to grow their business, a vital task that you can hardly afford with your limited budget and time.

Until now.

With 1 Business System - you don't need to hire more employees or buy more separate & complicated tools.

This is because the system integrates & automates your vital business activities saving you time and money.

Here's how 1 Business Sytem works...

1 Business System basically provides you an entire online business suite.

Think of it as having different business departments - all automated, working for you around the clock, 24-7.

-You want to create more sales leads & inquiries? Oh yeah!

-Need to record, track and see all your visitor & customer activity? Check!

-Are you selling physical or digital products? Bookings for your services? Got it!

-How about sending targeted emails? Got that too.

-You want to know what's happening to your business asap? No problem

- Assign tasks to your staff & sales people even when they are out of the office? Its got that covered for you.

All of these functions coordinate with each other something you cannot get when you buy separate ecommerce, crm & even email marketing systems.

Because 1 Business was built from ground up, all of the functions were designed to work with one another from the start.

Aside from that, there are so much more you can do with the 1 Business system such as:

Shipping integration,

SEO friendly URLs,

Multi-currency facilities

Payment gateways such as paypal, etc.

Create unlimited blogs & forums w

Web applications / apps

Modules such as photo galleries, Press releases, the list goes on.

And here's the best thing of all...it's so easy to use:

* Posting updates such as text, pictures & videos on your site is as easy as using a word processor

* Creating Web Forms, Web Apps, Modules and other cool stuff is easily done with just a few drag & drop actions.

You don't need any coding or programming skill at all.

Think about that...

A system that gives you all the tools your larger competitors are using but only:

- it's more powerful
- it's integrated (all systems 'talk' to each other)
- it's So easy to use

Correctly & effectively managed, 1 Business System helps make your business playing field so uneven & lopsided - all in your favor.

After all, if you can employ far superior capabilities than your rivals at a fraction of their overheads, manpower & size...your business will emerge far more profitable.

So take it from our hero David, it's not the size & bulk that matters, it's all having the right business elements & a silent yet powerful partner to take on the giants.

And oh, I almost forgot...you can try the system out for 30 days absolutely free. Yes, free with no strings attached. No credit cards, no contracts. You can even create several trial sites if you want.

So go ahead and give the 1 Business a spin by clicking here.

A CRM software for small business as well as medium to large enterprises

2010-06-01T06:58:00.000-07:00

Here's something to consider if you are planning to start your real estate brokerage / marketing business or any business for that matter.

What's cool with this system is that it replaces a lot of systems you will have to purchase separately but now everything is in one place.

There's a free trial so do check it out if it works for you. :)

Use Facebook Ads To Market Your Real Estate Listings

2010-05-25T10:00:00.000-07:00

If Facebook were a country, it can be considered the 3rd largest country in the world in terms of population as it has more than 400 Million users & still growing,. This would mean the popular social networking site would rank somewhere between India & the United States as per latest stats from Wikipedia.

(image from wikipedia)

So it doesn't come as a surprise that a lot realtors, agents & other businesses are tapping the potential of this ever growing social network to promote their listings, products and services.

However, while thousands are joining the bandwagon & try to leverage their presence in Facebook, it seems a great number of sales agents are spamming the network 'til kingdom come & expect to get instant results!

Well, if quick leads are what you're after, then there's only one sure fire way to do it. Pay for it!

Unknown to many real estate people, Facebook advertising is easy, relatively cheap & does bring in results. Within 15-minutes & just a few US dollars, you can advertise your properties without spending a lot of time & effort.

Of course, Facebook is no magic bullet but a properly executed campaign will bring great benefits to the advertiser. Combined with other paid (Google Adwords, banner advertising, etc.) and non-paid activities such as article writing, forum & blog posting, social bookmarking,video marketing, etc. you can get your listing noticed by your target market faster than ever.

So how does Facebook paid advertising work?

First, you need to setup your Facebook advertiser account at http://www.facebook.com/advertisin

Second, create a new ad campaign for your property listing by supplying the required data during the instructions carefully.

At this stage this where you need to optimize your ad in order for your prospective clients to discover & get attracted to your ad / offer.

Leveraging Facebook's user data (yep, your personal data as well as other activities inside the social network - likes, dislikes, etc.), you can drill in on your specific target market. Information such as location, demographics, hobbies, etc. can help you narrow down who you want to target.

Here's how it looks like:

At this point, you will also need to set up your advertising budget and mode whether you are going for Cost Per Click (CPC) or Cost Per Thousands of impressions (CPM).

You also need to fix your daily ad budget as well as your maximum bid for each click or per thousand of impressions and guess what? You can post an ad for just $1/day!

Of course, this goes without saying that if you need more clicks & prospective clients, you will have to increase your maximum bid as well as your daily ad budget.

I will discuss in a future post helpful tips in targeting your advertisements. For now, you just need to get the basic process of creating a Facebook ad.

Btw, one cool thing about Facebook Advertising is that you can add photos to go along with your ad so you need to be very careful & deliberate in choosing relevant and attracting images to support your message.

Finally, once you have complete the process by entering your credit card details for billing purposes, you ads now are good to go.

Just remember, you can pause or stop your ads anytime or even set a schedule to start & end your campaign.

So there you go, you have successfully created an affordable ad campaign for your real estate listings.

Good luck and happy selling!!

Making Money Online: Referral Marketers Needed

2010-05-08T02:25:00.000-07:00

Are You Making Money Online?

Would You Like To Learn and Earn Money Online?

Referral / Affiliate Marketers Needed!

(Hardworking Newbies Welcome Too!)

First: Good, BETTER & Great News For You.

THE GOOD NEWS:
This is NOT A Get Rich Quick Scheme, Pyramiding, MLM Or A Scam.

You have to work hard & smart using your link building, internet marketing (article writing, video marketing, blogging, social networking, etc.) & web-savy skills. Your offline & traditional selling and marketing talents will work well too.

The Only Way To Earn A Lot Of Money The Honest Way Is To Offer A Solution To People’s (or a niche) Real Or Perceived Problems.

THE BETTER NEWS: Our Product – 1 Business System is provides a compelling solution to business owners, executives & entrepreneurs’ sales, marketing & operations problems around the world.

With 1 Business System - you don't need to hire more employees or buy more separate & complicated tools.

This is because the system integrates & automates your vital business activities saving you time and money.

Think of it as having different business departments - all automated, working for you around the clock, 24-7.

-You want to create more sales leads & inquiries? Oh yeah!
-Need to record, track and see all your visitor & customer activity? Check!
-Are you selling physical or digital products? Bookings for your services? Got it!
-How about sending targeted emails? Got that too.-You want to know what's happening to your business asap? No problem
- Assign tasks to your staff & sales people even when they are out of the office? We got that covered for you.

So How Much Are You Going To Make?

June 2010 Promotion

Starter Plan = $4/sale
100 sales × 4 = $400 a month = $4800 a year

Plus Plan = $7/sale
100 × 7 = $700 a month = $8400 a year

Deluxe Plan = $11/sale
100 × 11 = $1100 a month = $13,200 a year

Professional Plan = $17/sale
100 × 17 = 1700 a month = $20,400 a year
200 × 17 = 3400 a month = $40,800

Normal (After The Promo)

Starter $3.60/sale
100 × 3.60 = $360 a month x 12 = $4320 a year

Plus = $7.60/sale
100 × 7 = $700 a month x 12 = $8400 a year

Deluxe = $10/sale
100 × 10 = $1000 a month x 12 = $12,000 a year

Professional = $20/sale

100 × 20 = $2000 a month x 12 = $24,000 a year
200 × 20 = $400 a month x 12 = $48,00 a year

Our primary market: Small, Medium & Big Business All Over The World

What Exactly Does The Product, 1 Business System Do?
1 Business System helps businesses grow by saving costs, powering up sales & marketing while streamlining operations as it gives entrepreneurs & executives more time to focus on their core activities - leaving the tech to the system.

1.) It Replaces 6 to 10 different independent systems an online and offline business requires with just 1 powerful business platform, saving them costs & time

2.) It Ends Business Owners & Executives frustrations of trying to get 6 to 10 different systems to ‘talk’ & coordinate with each other, ending up spending tons of money hiring tech people to integrate these systems to a company’s sales, marketing and admin operations

3.) It enables Businesses to monitor anytime what’s working and not working in their sales, marketing & other business operations.

4.) It gives the Business owners, Executives & Entrepreneurs the power to control their entire operation from one console – anytime, anywhere.

5.) It is so easy to use (WYSIWYG) that business owners, executive & entrepreneurs & their staff can use it themselves with no need to call their IT administrators or maintain outside tech guys all the time to make simple changes etc. If you know MS word, you can use it. It’s that easy.

Don’t Take Our Word For It.

Make Your Due Diligence Study On The 1 Business System

By Visiting The 1 Business System Home Page Now!

Here’s something better:

You can try it out for free for 30 days & give the product a test drive (don’t worry, no credit cards, contracts, etc. no questions, no B.S. - just a free trial. Period.)

Try The 1 Business System Now

For Free By Clicking On The Link.

UPDATE: Check Out Our June Promo For Early Birds!

GREAT NEWS:

1. For Business Owners - Flexible pricing & payment terms depending on your business needs

Powerful the system maybe but surprisingly it doesn’t cost businesses an arm & leg.

Basic paid plans start at $47 per month while the professional & complete version costs only $147/month. Businesses can save more by buying the annual plans (discounted) or even buying the entire system.

Use Your Existing Design If You Wish And Have Your 1 Business System Up And Running Within 1 Day.

2. For Affiliate Marketers / Referrors –

· Earn recurring monthly commissions for paid monthly plans (not the entire system) as long as your customers pay their complete monthly fees on time
· Get your own unique affiliate links!
· Everytime a prospect clicks on your link, your prospects information is stored up to 1 year and if they buy within the period, the sale will be credited to your account.
· Commissions are automatically routed to your paypal account after your buyer / referral completes & confirms the payment / check out process.

· We are behind you all the way. We will provide affiliates with training, sales tips and other skills to succeed. Our training modules have been developed by the top 1% of Internet Marketers around the world and you will get access to these materials for free,

You want to get started? Need more information?

Visit the 1 Business System site or Send Us An Email to:

clientmanager@online-marketingsolutions.com

Get to know our other services, visit:

http://www.online-marketingsolutions.com

Making Money Online: Referral Marketers Needed

ritche89.sulit.com.ph - Saturday, May 8, 2010

2010 © Sulit.com.ph

Essential Items Your (Real Estate) Website Should Have

2010-04-23T22:50:00.000-07:00

I've been asked often by colleagues (mostly the older ones) from the industry on what essential things their websites (or planned websites) should have in order to be successful in getting buyers interested with their listings. I always get surprised by these queries as I am not exactly the techie type though I do have several years experience with using the internet to sell properties than most of them. In any case, I share few useful pointers even if I ended explaining to them what those meant as a huge majority of them don't even know what SEO means.

So here's my short list of tips which is not really everything (to be more accurate about it, there tons of very useful and free stuff & tutorials out there on the web) but at least will give them the proper mindset:

1. Search Engine Friendly / Easy To Search - make your site easy for search engines to index. More than 90% of all property searches starts with search engines and unless google or yahoo or bing can easily find your site and make it to a searcher's query, your site might as well be considered as non existent.

2.) Photos - People who visit a site are looking for listings, properties, reviews. Unless you have relevant & nice photos, don't ever expect people to get excited about your listings. You can load pictures directly to your site or have them hosted on a photo sharing sites such as Flickr, Picasa & Multiply and free real estate advert sites just use the photo links to have them appear on your site or blog (see sample below from Ahyer.com):

3.) Complete Property Information - At the very least your site must have basic information of the house or property such as: exact location or address, no. of bedrooms, T&B, Lot & floor area, date constructed (for house), price (if possible), etc.

4.) Information / Inquiry Capture Mechanism - Whats the point of getting people pumped up with your hot offer when they don't have the means to contact you. Email address, telephone numbers, office address (if any) are very vital. You can easily get contact data by inserting a web form either for your newsletters or property inquiries. Just be sure to tell your visitors that you will not under any circumstance, sell or rent out their email address. If you hate spam, so do your visitors.

5.) Analytics - How do you know your marketing is working or not? The only way to do that is to have stats so you can measure your marketing success or failure. You don't have to cough out serious money for this as awesome tools such as Google Analytics are free! All you have to do is create an account.

6.) Videos - Pictures are nice but videos can do much much more. Videos engage viewers more than still photos. It also presents the property in a more realistic light which can enhance your credibility as well confirm to out of town prospects that your listings are real .

If you don't have one or some of these features, I highly recommend you add these to your site as you may be missing out a lot of potential property buyers. As mentioned earlier, there are a lot free stuff out there in the internet and all you have to is to use your trusty search engine to find these tools.

Now if you want something serious, you can also consider investing powerful systems such as 1 Buiness System. I bought & using one myself. This website system has a great package that you may need to set up a powerful real estate site as it's a complete suite. It has:

A Customer Relationship Management (CRM) system which allows you to management existing & new leads & customers. It tracks and even records all their interactions with your site. Pretty cool huh?
A very easy to use Content Management System (CMS) which basically the ability to update your site with new content/information, photos, videos or new pages. You don't need to be a programmer or have code skills to do this. If you know how to use MS Word and other word processing application, you are good to go!
Forums & Blogs - you can create as many blogs and forums as you want! Real estate clients have specific needs and wants & the key to success (as you have already known) in real estate is about communication, interaction and conversation. What could be more cool than to create a forum and blog for your clients so they can have a voice? :)
Email Marketing Campaigns - You can launch highly targeted email campaigns to your existing clients & prospects on your email list!
Search Engine Friendly features - I am no SEO expert but it has lots of stuff that you can tweak & making it easy for the search engines to index your content and real estate listings
Other features that you may or may not need: Ecommerce (sell stuff online such as real estate training ebooks), Analytics (you need this!), etc.

To see if this system is for you, why not take this baby out for a spin at 1 Business System.com. Try out all the features (after all, its free so why not make good use of it) and see if it meets your needs. You can unleash your creativity here.

If you have other ideas to grow this list of real estate website tips, please post a comment.

Environment-friendly House In Cebu

2010-04-09T08:30:00.000-07:00

Last February, my daughter Gabby and I visited Cebu City Councilor Archibald's Green/Eco House in the suburbs.

I was really impressed with the measures taken by the owner to use eco-friendly means to maintain his house. Check out the pics and see for your self. Note: please don't mind the date stamps, I messed up the date functions of the cam somehow :)

The Archibald Main House Front View

Solar panels provide electricity while rainwater catchments recycle the water for reuse. The Archibald family saves a lot from their electric bills with the use of solar energy and efficient use of natural cooling techniques.

Empty softdrink / soda cans look cool when used properly. The table is a cable wire spool!!

Water used on this swimming pool is recycled, cleaned and treated

This dome provides ventilation & cools the house as well as lighting

Those small windows helps lighting up the house, maximizing the use of sunlight

The different phases of the moon.

That's an empty baking soda container used as a cover for the lamp shade.

More lighting for the house

A view of the living area. Those holes are discarded PVC pipes and provide additional ventilation.

Closer look at the ventilation holes, viewed from the second floor

A banca / traditional canoe bench

Another cable spool converted to a table

Another view of the rainwater catch basin where Councilor Archibald also raises Tilapia & uses the excess water for his organic farming project.

Advertise On Facebook For Free...But Hurry Before The Offer Goes Pfffft!

2010-03-31T23:47:00.000-07:00

Yep, you read that headline right. You can advertise for free using the world's largest social networking site, Facebook.

A bit on Facebook advertising
For those still new on social network advertising (like me), you can post ads targeted to Facebook members using the network's database of 400 Million members (including mine and yours if you have an account). What makes this medium so powerful in my view is that you can choose both demographics (age, sex, location, educational level, job description, etc.) as well as psychographics (lifestyles, likes, dislikes, etc.) and even their membership in the different groups.

I have launched my first ever ad with Facebook the other day and I have no complaints so far with the results. I got 15 clicks in just 2 days, which is not bad given given that I had only 20,000 impressions (I chose the CPM per thousand of impressions instead of pay per click). Now that may seem too low for you but if you used a budget of only get this ---- $1.30/day...now that's a very high return as I am promoting the site builder I wrote about - yes, I am a believer now, so much so that I signed up as an affiliate. ( I will post more on the progress of my site using the Ezprofitresults system)

Btw, here's what my ad looked like:

Realtors and real estate agents who want to launch targeted ads should try this and evaluate if it is worth it.

Free stuff
Ok so here's the free stuff. Occasionally, Facebook and its partner sponsors give out free advertisement coupons / codes to the public as part of their promotions. Well, it so happened I stumbled on this blog: www.seoflexmedia.com last night and it gave away a $50 ad coupon for Facebook. So I tried the code and you know what...it worked!! I now have an extra $50 ad credits I can use to promote my stuff and properties.

Since I am so happy with my find, I am paying it forward...the free stuff and hope all of you benefit from it the same way as I did.

So here's the code: FB-SES-NY

Remember you need to create your Facebook advertisement first and put in your credit card details (you will be deduct something like a $1.00 for registration and space purposes) before you can activate your ad and use the promo code.

Don't worry, if you redeem the promo code for your ad placement, Facebook will not deduct it from your credit card (you may use a debit card as well as long as the issuers are Visa, Mastercard, Discovery or American Express).

Please do give it try and let me know the results. The advert code does have an expiry (mine is about 60 days) and you can only use that to place ads in Facebook.

Happy Selling!!

Powerful Website Builder

2010-03-31T06:17:00.000-07:00

Last week I wrote about the free trial website online business builder software called the Ezprofitresults I am using to build my CNP Properties site. Although I am no programmer, I found it easy to put in content such as images, text and even embed videos to the site.

In case you want to see the functionality and features of the system, here's a video describing the what you can do with it.

As you can see, the Ezprofitresults system has a lot of applications for a whole range of businesses. For real estate it be a powerful tool although again, these are just that - tools.

Real estate still remains and will also be people business and unless your site touches & mean a lot (being very relevant to their needs) to people, it won't be successful at all.

Good News For A Change: BBC Fast Track Visits Cebu

2010-03-26T23:36:00.000-07:00

My Florida-based cousin Bitoy (who is an accomplished photographer- check out his blog & portfolio here aside from being a top notch medical technologist) posted a recent BBC video on Philippine tourism link on his Facebook profile. You can view the video by clicking on the photo below(sorry no embed feature):

http://news.bbc.co.uk/2/hi/programmes/8569932.stm

Though the video exclusively showcases Cebu, I believe we should have more of these features and information to promote other exciting destinations. As one American expat resort operator said, we need more publicity not more ads to counter the usual negative stories circulating about the Philippines. Tourism Secretary Ace Durano (incidentally a Cebuano himself) also revealed a basic marketing tactic to draw more tourists: focus more on the destination than the country itself. The Philippines seems to have a bad rep that it smarter to promote Bohol or Cam Sur as a stand alone product. Cebu has been very successful with that tactic during the late 1980s to the early 1990s where its tagline was: Cebu - an island in the Pacific. It's was an ingenious marketing move, to position the destination away from the negative publicity especially during that time when coups, disasters, typhoons and violence were synonymous with the Philippines.

Ultimately, in the age of web 2.0 its not the ads that will draw people to come and visit but its the stories, user experiences and other media shared by people who are happy and satisfied with what they have seen and tried. The government should capitalize on social media to spread the word by mouth...or in this case by Facebook, Twitter and other tools.

Real Estate Site Building Progress Using The Free Trial

2010-03-23T00:26:00.000-07:00

Here's some screenshots I took as I went about editing and playing around with Ezprofitresults, online business platform which gives you the tools to create not just a site but also forums, blogs, e commerce, perform email marketing and many more.

Here's a cool feature...you can edit the entire site using a very easy WYSIWYG interface. Just click on the region you want to edit or update, then you are good to go. Very intuitive if you ask me.

How do you like this theme for a real estate agency?

How To Build Your Own Online Real Estate Business Without Programming Knowledge Part 1

2010-03-20T06:17:00.000-07:00

I'm trying out a free 30-day trial service from a site called ezprofitresults which allows me to create a fully functional web site for my real estate agency CNP Properties though from its features, it can be called a total online business as it not only creates a site but also other funcationalities needed conduct moden online business transactions such as blogs, forums, e-commerce and a host of other cool stuff.

What I really like about this service so far is that I was able to choose from a lot great templates they have on stock and build the site from ground up. And although I have yet to try the other features of the service, I am attracted to the ease of use, something similar to like creating posts for a blog.

Here's what the template I choose looked like:

Old School Web
I started to use the internet to promote real estate back in the 1990s using the Geocities.com free service. I named the site, Visayas Property Link. At that time I believe (correct me if I'm wrong) Geocities was already part of the Yahoo network which made it convenient for me to just sign in using my yahoo id, which btw I still use until now.

At that time, the purpose for that site was to post pictures, content and other data on Manville Royale and other Bacolod properties for sale. I didn't want to put up that site but I got so tired attaching those files to my client emails (it was all dial up then) which prompted me to post all the infos.

The one thing I really liked about geocities was that it was so easy to use. It was like using Word or Power Point where you just compose your message, add photos, links and you have a brochure-type site running in no time. If you want to add new pages, you just click add a new page and do the usual stuff and link it to the main page or index. Btw, the screen shot on the left shows that my geocities site looked like as I retrieved it from archives.org.

That site really helped & got me regular monthly streams of leads and sales. Back when everybody was trying to learn email and discover the internet, I was already spending hours and hours a day developing and posting content to the site so much as that it ranked high up in yahoo's search engines (no, google then in the late 90s and early 2000s). As time passed, I added more and more pages for Iloilo and Cebu properties which got me more sales from the leads generated. Many of those buyers who bought their propeties from me ended up being my life long friends who I still communicate to this very day

Of course, there are a lot of downsides. First, you cannot expect your site to be really professional looking with just the simple functions and options unless you really take time (which I don't have as I am busy selling houses and other properties) to learn tricks and other neat stuff. Second, there are the usual problems with free sites. You remain at the mercy of the owner who might one day give up the service and bring down your entire internet business down crashing.

Which is what happened to geocities. When geocities decided to fold up, along with it my valuable data and as well as my steady stream of leads and property inquiries.

Although geocities made the announcement months before the scheduled closing, I hardly had time to prepare on what to do as I was already getting ready to move and strike out on my own.

To keep my online presence, I tried new property website advert sites starting to profilerate around the web and so far, the results have been fairly ok. I would personally recommend sites such as : Sulit.com.ph, Bahay.ph, iproperty.com and Ahyer.com.

New generation sites: web 2.0 for real estate

However, despite effectivity of these free advert sites, it doesn't change the fact that its about time I needed a real deal site and not just any website. With the presence of so many web services that allow people to share information and particpate in forming new information on real estate, I knew I have to come up with something that would allow me to:

1. access analytics data (no. of visitors, from where, etc.)
2. keep track of my leads that come in through my web site inquiry form
3. launch email marketing campaigns
4. create a blog
5. build a forum for discussions
6. manage and update my site easily without going to a webmaster or developer to do it for me.

Thus I scoured the web for services that allow me to do so and there are a lot of those available. You have applications such as Wix, google sites among others but again, what I needed was a more updated system that would allow me to converse with customers and house my daily selling activities such as emails, monitor my agents output and inputs, etc.

Ezprofitresults looks promising but I will still test it further and post more updates very soon.

Bacolod Real Estate Videos, Pacific Shores in Talisay, Negros Occidental

2010-02-13T08:38:00.001-08:00

Here's Video No. 2 for real estate subdivisions / developments around Bacolod.

If you like the idea of living in a residential beach village near Bacolod City, then this development maybe for you.

I have always liked this subdivision. It's not too big or too sprawling which is ideal for cultivating close neighbor relationships, underground facilties (yes, and I mean power, telephone, etc.) - look Ma...no hanging wires! And of course, it has nice amenities in a beach front setting.

I've made 2 videos for Pacific Shores, the first was way back in 2008 (with all the shaky hands and unstable focus) as shown below.

Here some amazing photos of the site just to show you how awesome the place is:

Bacolod Real Estate Videos

2010-02-13T07:51:00.000-08:00

I have created a few videos for subdivisions and real estate services in Bacolod City. I will start posting / uploading them here. I hope you enjoy these flicks as much as I have making them.

Video No. 1
This video is about House Construction services offered by Avanti Homes Development Corp.

What's so cool about this company is that you can choose any house model in their inventory to be built on your existing lot. If you don't have a lot, you can purchase one in any of the better developments in Bacolod. Avanti has no problems building houses in the following subdivisions: Ayala North Point & Plantazionne both in Talisay City,Negros Occidental (just 5 minutes from Robinson's Mandalagan); Manville in Tangub (going to Sum-ag & Bago City in the South), Oasis Subdivision (right next to the Coca Cola Plant, going to Mambucal), Pacific Shores also in Talisay (you can't miss it going to and from the airport in Silay...it's an awesome beach front residential development), Negros Occ.

Excellent Bacolod City Video!

2009-12-17T18:59:00.000-08:00

Just finished watching an awesome video created by the Negros Island Toursim, Inc. No words needed for that presentation, the sights and sounds spoke for themselves. I hope you'll enjoy watching it as much as I did.

NITI - Bacolod City Tourism AVP from Gary Lake Liza/Leo Vision on Vimeo.

Pinoy Real Estate Marketing Today & Tomorrow

2009-10-31T04:13:00.000-07:00

Few Filipino agents and real estate brokers today have realized the the industry they have come to know & love for the past 5, 10 or even 20 years is about to undergo dramatic changes that will make the future of Philippine real estate marketing so unrecognizable by today's standards.

Pinoy real estate practitioners may like it or not, but there is no way to avoid change and change... is often said to be very disruptive.

Disruptive doesn't necessarily mean it is destructive. Disruption through innovation and better technologies is actually a powerful creative process. A lot of things we currently enjoy now in our daily lives are the results of introducing disruptive innovations & technologies. Of course, the old order and it's entrenched beneficiaries feel threatened with any kind of innovation that comes from an unexpected direction. It would be like Betamax or the VHS video formats, feeling threatened with the introduction of Video Compact Disks, a product that drove video cassettes to extinction (and VCDs in turn are about to be confined to history's dustbin when the first DVDs came along).

Such will be the case with Philippine real estate service in the coming years. New and disruptive innovations as well as new realities will shake up the present status quo and it's no surprise that the principal ingredient for these changes to occur are already in place. We can expect a lot more innovations to take root & slowly but surely alter the way agents, brokers, developers, buyers, sellers and as a whole the entire public view handle real estate transactions.

To be more specific, I would like to cite a few game-changing events, trends, innovations & realities that will surely bring about real change:

1. RESA - Real Estate Service Act of 2009 (or Republic Act 4696).
2. Widespread use of the internet and the information technology
3. The Global Financial Crisis that started with US housing crash
4. Worldwide changes in demographics and migration
5. Emergence of niche markets and marketers

I am certain that there are other events, innovations and realities that will dramatically affect how real estate agents, brokers, sellers & buyers in the Philippine transact or do business and I encourage readers of this post to contribute their views on the matter. For now, I will just focus on these 5 areas in my coming posts and give my insights on how & why these will really change the real estate game forever.

2009-06-23T06:25:00.001-07:00

SELLING A PROPERTY IN THE PHILIPPINES: CO-OWNERSHIP

Real property sold whether held by one or more owners in the Philippines undergoes a process required by law & payment of taxes & fees in order for sale to be valid as well as properly registering the property to the new owner or the buyer.

Preliminaries

To ensure smooth sale of the property, it is advisable that following important documents be prepared:

1.) Transfer Certificate of Title (TCT)/Original Certificate of Title(TCT) also known as the Torrens Title must have no liens (legal attachments or impediments), lis pendens (title is subject of an going legal proceedings) and claims. If there are liens and claim, this should be settled first as the buyer would question this and would hesitate in getting involved in such cases.

It is also advisable to secure a Certified True Copy of the title from the Registry of Deeds or ROD (at the Hall of Justice or Courthouse) so that potential buyers can also verify the Original ROD Copy.

2.) Real property taxes to the city – it is advisable that these should be updated and all receipts & tax clearances secured before consummating a sale. Payment and securing of taxes and clearances can be done at the City Treasurer’s Office in City Hall.

3.) Updated Tax Declaration – A Tax Declaration is document issued by the City or Local Government stating the existence of the property, it’s primary use/zoning and underlying assessed vale for taxation purposes. Updating of Tax Declaration for both the lot and the house (if any) can be done at the City Assessors office in City Hall.

4.) A lot plan signed (with seal) by a geodetic engineer or surveyor.

5.) If there’s no house or improvement on the lot, a Certification of No Improvement has to be secured from the Assessor’s Office in City Hall.

6.) For co-ownerships, for ease of transactions, appointment of an Attorney-In-Fact (AIF) one of the owners by virtue of a Special Power of Attorney (SPA) will be issued by the other selling co-owners, authorizing the AIF to negotiate, transact, sell receive payments & monies as well as sign all pertinent documents, contracts and other papers related to the sale of their shares or portions of property. If there are specific conditions on this authority to limit or expand such an authority, this can also be written on the SPA.

The SPA can be prepared by a lawyer or there are proforma SPA forms which can be used for such a purpose. However, the document should be notarized by a notary public or a lawyer. Each co-owner can issue separate SPAs appointing the same person as the AIF or a joint-SPA can be prepared wherein all the co-owners can sign on a single document.

If any of the co-owners are located abroad or outside of the Philippines, the selling co-owner may go to the nearest Philippine Consulate and have the SPA prepared by the consular officer who will notarize the said document.

In some cases, a local notary of the home country and authorized by the Philippine Consulate can notarize the Special Power of Attorney but the same document will have to be authenticated by the Philippine Consular Officer in that country.

Sale of Property with consent of all co-owners

Once a meeting of mind between the selling property co-owners or the AIF and the prospective buyer on the price, terms and other details, the sale is considered. Payment of the property can be done either direct payment to the AIF or separate checks issued to the names of each owner and to be received by the AIF if the SPA authorizes him or her to do so. Once full payment for the property is issued, co-owner sellers or the AIF are obliged to sign the Deed of Absolute Sale and turn over all pertinent documents to the buyer including but not limited to: the Original Owner’s copy of the TCT, the Tax Declaration, Tax Receipts and Clearances.

Closing costs are usually shared among the seller and the buyer. Breakdown of closing costs are as follows:

Seller pays: Capital Gains Tax (6% of the Total Selling Price in the Deed of Sale or the Zonal Value, whichever is higher) & Documentary Stamp Tax (1.5% of the Total Selling Price or the Zonal Vale, whichever is higher). If the seller’s hired a broker for the sale, licensed brokers are entitled to a commission or broker’s fee of 5% of the Total Selling Price. The Capital Gains tax & Documentary Stamp Tax are payable to the BIR and should be paid within 30 days from date of notarization of the Deed of Sale.

Buyer pays: Transfer Tax, Registration, Notarization of the Deed of Sale, and other fees related to the transfer and registration of the property to the new owner’s name.

Once the Deed of Sale is signed, full payment of the property received and all the taxes and other obligations of the seller are settled, the sale is no considered final and closed.

Sale of Property without consent of all co-owners-OPTION A, Subdividing the Property

First step is to inform all the co-owners on the planned partition of the property. This can be through a legal counsel or even in writing by the AIF of the selling co-owners to all the co-owners especially the non-selling co-owners. However, it is advisable that a lawyer be employed to execute this.

Once all the co-owners are informed including the non-selling co-owners, a geodetic engineer or surveyor is contracted to conduct the survey, partition and taking down of the necessary technical descriptions. However, it is also during this stage that inputs from the non-selling co-owners must be taken into account so that the positioning and the allocation of lots and the question of who gets what is resolved. These inputs will be incorporated in the subdivision plan to be prepared by the geodetic engineer.

The subdivision plan is then presented by the geodetic engineer to all the co-owners, including the non-selling co-owners who will sign and approve the plan. An application for subdividing the property is then sent to Bureau of Lands for the approval. This could take several weeks. Some fees also will have to be paid out to the Bureau.

Upon approval of the technical descriptions & bearings as well as the entire subdivision plan, then the original title & other documents (tax declaration, tax receipts, etc.) will then be submitted to the Registry of Deeds along with the approved subdivision plan issued by the Bureau alone with legal documentation proving that all co-owners approve the partition. The Registry of Deed then cancels the old title & issues new titles for the subdivided lots.

Selling co-owners may now proceed to sell the property to other parties once a new title is issued for the new lots & the process is similar to that as described earlier for selling co-owned properties with all the co-owners consenting to the sale.

Sale of Property without consent of all co-owners-OPTION B, Co-owners selling their share on the common property without subdividing the lot

For this option to work, a legal counsel is highly recommended.

Selling the property directly to the open market with the other co-owners not giving consent may discourage potential buyers since there is an element of risk on the part of the buyer as he or she will not get to have absolute ownership of the whole common/undivided property required for whatever purpose they see fit (residential, commercial or industrial).

One option worth exploring would be to go to court and invoke the provisions of the Civil Code (Article 491) wherein the minority shareowners are withholding consent and have their lack of consent has been prejudicial to the interests of the vast majority.

Since the decision on the issue of selling without consent of the others is best suited to the courts, again, a lawyer is needed in this case.

2009-06-23T06:10:00.000-07:00

SELLING A PROPERTY IN THE PHILIPPINES: CO-OWNERSHIP

Aside from the usual sales discussions & presentations on real estate subdivisions projects & brokerage, be it lot for sale or house and lot or a condo or a townhouse, in Bacolod, Iloilo & Cebu, a lot of customers and even non-customers & friends consult me on matters regarding real property ownership in the Philippines. Since land ownership is a real touchy issue, especially among Filipinos (think of the numerous rebellions, insurgencies, family feuds, court cases & other disputes all rooted on land & its ownership), I usually refer sensitive legal issues to the experts (meaning...lawyers). However, as a practicing licensed real estate broker/realtor (in Bacolod, Iloilo & Cebu), I feel it is my obligation also to share whatever knowledge I have on the subject as the law is quite clear with regards to property ownership. For this post, I will focus more on what is called co-ownership.

The Philippine Civil Code (Article 484) states that co-ownership or tenancy-in-common occurs when the ownership of an undivided thing or property belongs to different persons. As such, it means that rights of the co-owners are inseparable, as if they are one; therefore one may not dispose of his or her interest in the co-ownership without the consent of other. The concept of co-ownership arises only when the property or thing is undivided and doesn’t apply when the portions or shares of the different co-owners are readily identifiable, delineated or concretely determined even if there are no ready technical descriptions yet available[i].

Co-ownership is also a form of a trust wherein the co-owners are the trustee of the other. When a co-owner dies, the surviving co-owner or co-owners is subrogated (or automatically assigned) to the rights of the deceased owner.

Rights of Co-owners

A co-owner’s rights or interests are classified into 2 categories. First is the ideal or abstract (non-physical) part of the undivided object, thing or property and second, rights over the physical thing itself. The co-owner enjoys full ownership of his/her portion or share and is entitled to enjoy all the fruits & benefits pertaining to that object or property. He or she can mortgage, sell, exchange, lease or even assign his share to another to another party[ii]. However, the mortgage, sale or assignment of the property or thing is limited only to the portion allotted to him or her[iii].

The Civil Code states that no co-owner shall be obliged to remain in the co-ownership (Article 494). Each co-owner may demand at any time the partition of the thing or property owned in common, insofar as his share is concerned. However, co-owners also cannot demand a physical division of the thing or property owned in common, when to do so would render in unserviceable for the use it was intended (Article 495).

Sale or alienation of property by a Co-Owner

Acts of alienation or sale of a thing/property owned in common are decided on the basis of unanimity. A co-owner as a rule must seek consent of other co-owners is he/she intends to sell his share but this doesn’t mean that a co-owner cannot sell his portion or share. He/She always has the right to do so. If, the withholding of consent by one or some co-owners is clearly prejudicial to the common interest, the courts may grant adequate relief in this case (Article 491, Civil Code)

What are the effects of a sale of the whole property without the consent of the others, or if they do not give consent? The Philippine Supreme Court gave the following rulings[iv]:

a.) The sale will affect only the share of the selling co-owner or co-owners but not those of the other co-owners who did not give consent to the sale;
b.) The co-owners may seek a partition of the thing or property;
c.) Laches (a principle of law wherein a party asserts that an opposing party has "slept on its rights’) may not stop the other co-owners from claiming their rights on the co-ownership if they are unaware of the sale and there is absence of opportunity to oppose or take proper action;

The Philippine Supreme Court also ruled on a case wherein a co-owner sold the entire property without the consent of the other co-owners. The Court said it will not render the sale null and void since a co-owner is entitled to sell his undivided share. Only the rights and share of the selling co-owner is transferred to the buyer, thereby making the buyer a co-owner of the thing or property. A remedy of the complaining co-owner is the partition of the property in question and not an action for the nullification of the sale of the property or for the recovery of possession thereof[v].

Options and Courses of Action

Co-owners seeking to sell their property & may encounter resistance or even withholding of consent from other co-owners may base their actions on what is provided by law & the courts. Aside from the legal aspect, there are practical & economic to be considered before deciding a course of action to sell the property.

a.) Sale of the common property jointly by all co-owners at the same time to a single party

This is the ideal scenario as all the co-owners agree to sell all the shares jointly & simultaneously as one transaction to a single party. For real property, this mode provides the co-owners a lot of advantages, among these are:

1.) Uniform price, terms & conditions making it easier for a buying party to negotiate and consummate the transaction. All co-owners regardless of portion or share percentage will get to enjoy the best market offer.

2.) Documentary requirements are simple as the co-owners usually appoint a co-owner as an Attorney-In-Fact (AIF) & issue a Special Power of Attorney (SPA) to transact with the prospective buyer with explicit instructions on the details of the sale. The AIF will report & consult with the other co-owners on any counter-offers, concessions & other valuable insights on the sale.

3.) Prospective buyers deal with only one or at the most two co-owners during negotiations instead of many making the transaction smooth & productive.

4.) Upon meeting of the minds of the buyer and the seller on the sale of the property, the AIF may also sign all the pertinent documents, contracts and other papers related to the sale of the property if the SPA authorizes him or her to do so. Co-owners may also designate one AIF to negotiate the sale & another co-owner to sign the sale documents and contracts if they wish to do so.

5.) Payment of closing costs, taxes and other fees are shared by everyone on a pro rata basis (ratio) based on the each co-owner’s share

b.) Subdivide the property to delineate the portion of the co-owners who are willing to sell from the share of those who are not interested in selling. Once the two plots are issued separate titles, the co-owners who are willing to sell can proceed with their transaction & sell jointly the remaining portion to a single party.

For properties with large lot areas, this option may also be the next best thing to selling the property jointly & simultaneously. However, for small plots, this may turn out to be an expensive operation in relation to the value of the property as a whole if undivided and also the chances of succeeding of selling very small portions to the open market may prove to be slim.

There are two (2) major issues to be tackled first if this option is to be considered:

1.) For small lots with many co-owners & each with varying percentages of ownership share, the issue of marketability of the lots to other buyers has to be addressed.

To illustrate:

If a 200 square meter property with dimensions of 10 meters frontage & 20 meters depth gets to be subdivided among 3 co-owners with equal shares of 33.33% of the property, the most logical & equitable way of subdividing would be to end up with 3 lots with each plot having a total area of 66.67 square meters and dimensions of 3.33 meters of frontage & depth of 20 meters since it is assumed that each plot should have a road frontage.

Problems occur should two (2) of the co-owners decide to sell their share separately, it would be quite difficult to find buyers in the open market willing to purchase a 3.33meter x 20 meter property for residential purposes if the property is located in a residential area. The property would look more of a pathway than an ideal location for any house or home. If the property is located in a commercial zone, it even gets more problematic since businesses require adequate frontages for customer visibility & access of logistical equipment such as delivery trucks and parking space.

Should two of the co-owners decide to sell jointly their shares to a single buyer for a single use, then the chances of selling the property is improved but not much since the resulting dimensions will still be at 6.67 meters by 60 meters, barely enough for a parking space or entry for a medium sized delivery truck or an SUV. Depending on the location of the property and its best use, there may still be people who may purchase these small plots with small frontages. Next door neighbors looking to expand their areas may be interested & if it’s within the vicinity of a public market, small scale entrepreneurs may also consider the property. However, we cannot expect pricing to be maximized since the advantages of a wide frontage is absent in this case.

Overall, if the resulting smaller lots would diminish the marketability & even the value of the property, then this option may prove to be counter productive in the long term.

2.) Costs & Time Spent to Subdivide the Property

Subdividing a property entails costs as well as a lag time for the final subdivision plan to be approved and titled.

The process of subdividing normally occurs this way:

*First, a surveyor or geodetic engineer is contracted take the technical descriptions and bearings of the proposed subdivision plan.

Co-owners will have to settle among themselves who gets which portion or subdivided plot of the proposed subdivision plan if they intend to sell their portions separately. A resulting plot may have inherent advantages over the other smaller plots. A particular lot maybe much nearer to an existing commercial establishment, which is good, if the dominant use is commercial or another plot maybe right next to a open drainage canal which is not a good thing. In any case, the co-owners will have to resolve this amongst themselves.

*Second, once the issue of who gets what portion is settled and the geodetic engineer is done with his survey and recording of the technical descriptions and bearings, an application for subdividing the property is then sent to Bureau of Lands for the approval. This could take several weeks. Some fees also will have to be paid out to the Bureau.

*Finally, once the technical descriptions are approved, then the original title & other documents (tax declaration, tax receipts, etc.) will then be submitted to the Registry of Deeds along with the approved subdivision plan issued by the Bureau alone with legal documentation proving that all co-owners approve the partition. The Registry of Deed then cancels the old title & issues new titles for the new smaller lots. Again, certain fees will have to be settled for each of lots with the Registry of Deeds.

Compared to selling the property undivided, subdividing can be quite an expensive proposition given the process involved. However, if the lot is big enough and is situated in a good location, then the expenses are worth it. Real estate developers subdivide and sell smaller lots and still make profit especially since they purchase the plots at low price and introduce improvements that would enhance the quality of the entire location as well as raising surrounding values of the local community. On the other hand, for small plots, say at 200 sq.m., a lot of consideration should be given if the expenses and the potential returns are worth it given the lengthy process and other costs.

c.) The selling co-owners can always offer their share to the other co-owner unwilling to sell or subdivide their share.

This option is quite simple and doesn’t need to be mentioned but it’s worth exploring also. Prices and terms can be easily be negotiated by all the co-owners.

If a sale does occur, a Deed of Sale will be executed wherein the selling co-owners surrender and relinquish all claims, rights & interests over the property. Payment of the appropriate fees & taxes on the sale then follows. The original title is then surrendered to the Registry of Deeds who will cancel the old title and issues a new one in favor of the acquiring co-owners with their respective shares reflected.

d.) The selling co-owners may also sell their share in the common property without the consent of the other co-owners.

As mentioned in the Civil Code & other Supreme Court decisions, a co-owner has the right to sell his share anytime even without the expressed approval or consent of the other co-owners.

However, it is recommended that this option be taken as a last resort and would need to be done with the advice and supervision of a legal counsel. This is to prepare the selling co-owner of whatever legal actions that may be initiated by other co-owners who don’t give their consent. There is also the issue of relationships & sensibilities that maybe offended. Although this is an exercise of one’s right to do as one sees fit to one’s shares, nevertheless, extra caution through the help of a lawyer is highly recommended.

Another issue to be considered is marketability of a co-owner’s share in an undivided property to prospective buyers. Normally, buyers would want to purchase properties free from any future complications and would like to exercise absolute ownership (no co-owners/fee simple) rights over a property especially if it is residential. Though the law recognizes the right of the co-owner to sell his share in the common property, the buyer will end up being a co-owner of the property together with the other non-selling co-owners. It is now a question on whether a buyer, especially in the Philippines, is willing to go into a co-ownership arrangement with people he may or not get along.

e.) If the other co-owners insist on not giving their consent to the sale of their shares on common property, the selling co-owners can go to court and show that their withholding of consent if prejudicial to the common interest of the entire group.

For this option, a selling co-owner will need legal counsel as this involves going to the court and proving that the refusal of the other co-owners to consent to the selling of the entire common property is prejudicial to the interests of the co-owners holding more than a majority of the shares or portion of the property.

Summary

Co-ownership is recognized by law in order for co-owners to enjoy the fruits & benefits of its commonly owned property. As much as the courts recognizes the need to have unanimity in decision making as far as selling of a co-owner’s share or portion in a thing or property, it is also equally important that the rights of a co-owner be respected and the law has provided several avenues for this rights to be respected in numerous decisions and other articles in the Civil Code.

To sell a share or shares/portions in a common property, there are several options available which may be legally feasible but would be not be making sense from the economic and practical view point to the selling co-owner. For small properties, there are also physical limitations such as the area and resulting dimensions if subdivision of the common property is to be undertaken for the purpose of sale.
Co-ownership from the business/financial & even personal standpoint is a very good investment strategy for prospective property owners who may want to take advantage of opportunities in the market but lack immediate personal resources to make their purchase. For family members or heirs who want to preserve the family estate (and unity) for their children, co-ownership provides a common bond among kinsmen, a shared legacy which will be carried on by succeeding generations. The law is very clear on the issue on co-ownership and I advise not just my real estate buyers for subdivision properties & individual real estate in Cebu, Iloilo or Bacolod but for all owners of properties around the country to be aware and conscious of their rights as well as their obligations in a co-ownership arrangement.

[i] Spouses Si vs. CA,135 SCAD 754,342 SCRA 653
[ii] Villanueva vs. Florendo, 139 SCRA 329
[iii] Civil Law: Property, ownership and its modifications, Justice Jose C. Vitug,
[iv] Bailon-Casilao vs Court of Appeals(160 SCRA 738)
[v] Tomas Claudio Memorial College, Inc. vs. Court of Appeals (114 SCAD 58, 316 SCRA 502)
http://www.chanrobles.com/civilcodeofthephilippinesbook2.htm

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