Angelo Lopez III

09/07/2025

Sa lahat ng naka alala at bumati kahapon sa araw ng aking kapanganakan, maraming salamat po.

09/07/2025

Angeles City Water District (ACWD) Board of Directors, GM Pay Courtesy Visit to Mayor Carmelo
"Jon" Lazatin II | Angeles City Hall | July 9, 2025

📸 Angeles City Information Office

09/07/2025

09/07/2025

07/07/2025

Thank you for the gift of life.

04/07/2025

The (SC) has clarified that the salaries of public officials can be garnished—or legally collected—by the courts to pay off their debts. These salaries are not exempt from garnishment under current laws and rules.

In a decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division ruled that the salary of Atty. Fred L. Bagbagen, a Baguio City councilor, can be garnished to pay his debt to respondent Anna May F. Perez.

Bagbagen was cleared of criminal charges for estafa, but the Regional Trial Court (RTC) still found him civilly liable and ordered him to pay Perez PHP 308,000. The RTC allowed the garnishment of his salary, which was then withheld by the Philippine Veterans Bank.

Bagbagen attempted to stop the garnishment, arguing that his salaries should not be collected due to public policy reasons, and that these funds were still considered government property until spent.

The SC affirmed the ruling of the trial court and the Court of Appeals that once a public official’s salary is deposited in their personal bank account, it is no longer considered government money.

It emphasized that there is no law exempting public officials’ salaries from garnishment. Under Rule 39 of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘰𝘶𝘳𝘵, salaries – whether in the public or private sector – can be garnished to settle debts.

An exception exists for manual laborers, whose wages are protected to ensure they can still support their families. The SC explained that manual laborers “usually look to the reward of a day’s labor for immediate or present support, and such persons are more in need of the exemption than any other.”

However, only up to four months’ worth of wages are exempt. Any amount beyond that can still be collected to pay debts.

Read the full text of the Press Release at https://tinyurl.com/44u5fp2s.

Read the full text of the Decision at https://tinyurl.com/4pzbvsv9.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

03/07/2025

The (SC) has found two managers of a pizza restaurant guilty of simple theft for having kept service charges that should have been paid to the restaurant’s employees.

In a Decision written by Associate Justice Antonio T. Kho, Jr., the SC’s Second Division sentenced Janice Teologo and Jennifer Delos Santos, two store managers at the Shakey’s branch in Angono, Rizal, to 6 months in prison. It also ordered them to pay their fellow employees the withheld service charges.

One of Teologo and Delos Santos’ duties as managers was to give the employees their salaries and shares in the service charges. However, employees of Shakey’s Angono branch reported to franchise owner Big G Philfoods & Entertainment that they had not been receiving their share of service charges.

The employees claimed that notwithstanding this, they had been made to sign payroll documents indicating that they received their shares. They said that according to the store managers, this was pursuant to an alleged company policy.

While the trial court and the Court of Appeals convicted Teologo and Delos Santos of qualified theft, the SC modified the conviction to simple theft.

The 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 provides that the crime of theft is committed by one who takes something that belongs to another without permission, intending to benefit from it, without using violence or force. Theft becomes qualified when it involves the abuse of trust or confidence.

In this case, while the store managers took the service charges meant for the employees, the SC clarified that the victims were the employees, not the employer Big G Philfoods & Entertainment, Inc.

Since there is no special trust relationship between managers and rank-and-file workers, there was no abuse of trust or confidence in this case that would have qualified the theft.

Read the full text of the Press Release at https://tinyurl.com/2f6a4tvb.

Read the full text of the Decision at https://tinyurl.com/36vavmjv.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

03/07/2025

The (SC) has ruled that an acknowledgment receipt cannot be considered a contract of sale unless it clearly shows that the seller intends to transfer ownership of the property to the buyer.

In a decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division ruled that the agreement between Virgilio B. Chavez and his fellow petitioners (Chavez family) on one hand, and Spouses Joselito and Adriana Gopez (spouses) on the other was a contract to sell, not a contract of sale.

The case involved two properties inherited by the Chavez family, which they agreed to sell to the Spouses Gopez for PHP 31.5 million. The spouses were required to pay PHP 5 million as downpayment and to prepare the necessary documents, including the contract to sell.

The spouses initially paid PHP 200,000, noted in an acknowledgment receipt as “earnest money.” This receipt was the only proof of their agreement.

Later, the Chavez family canceled the agreement, claiming that the spouses had not paid the full down payment and had delayed the paperwork. This led the Spouses Gopez to file a case to force the Chavez family to proceed with the sale.

Ruling that the transaction was a contract to sell, the SC explained that in such a contract, the seller does not agree to transfer ownership of the property just yet. The seller only commits to fulfilling their promise to sell the properties and transfer title to the buyer after an event, typically the full payment of the purchase price. If this does not happen, their obligation to sell does not arise, and the seller retains ownership of the property.

In contrast, a contract of sale clearly shows the seller's intent to transfer ownership to the buyer.

In this case, the acknowledgment receipt did not include any promise to transfer ownership. It only showed that the spouses needed to meet conditions: the payment of the purchase price and preparation of the contract to sell, deed of sale, and estate settlement.

Read the full text of the Press Release at https://tinyurl.com/3zfynpbc.

Read the full text of the Decision at https://tinyurl.com/4hvfm3ze.

Read the the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://tinyurl.com/msysydyb.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

30/06/2025

“Majority of Filipinos support the Philippines’ return to the International Criminal Court, a recent survey found.”
- Inquirer.Net

29/06/2025

“Court rules Alice Guo ‘undoubtedly Chinese,’ erases mayorship.”
- Rappler

28/06/2025

“Every setback is a setup for a comeback.”
- Remez Sasson

27/06/2025

The (SC) has ruled that a land sale made through a verbal, unwritten agreement can be considered valid and binding—as long as it has been partly or fully carried out.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division upheld the verbal sale of land between Marcos Batara (Batara) and his nephew Benedicto Ocampo (Ocampo). Even without a written contract, the SC found the sale valid because Ocampo had already received the land title, moved into the property, and made improvements on it.

The land was registered in the name of Batara, who passed away in 1974. His children, Noblesa and Ernesto, only learned of their father’s ownership of the property in 2007, when they received a notice to pay unpaid real estate taxes on the land and found out that the same was being occupied by their cousin, Ocampo.

Noblesa and Ernesto filed a case to reclaim the land from Ocampo, saying they were the rightful heirs. Ocampo, on the other hand, claimed he bought the land from Batara while the latter was still alive. After Batara died, Ocampo kept paying installments to Marcelo, Batara’s brother.

Ocampo admitted that the sale was not evidenced by any written document because Batara died before they could execute the necessary instruments. But Ocampo provided the owner’s copy of land title as proof, claiming Batara gave it to him after the initial payment in 1972.

Ruling in Ocampo’s favor, the SC said that under the Civil Code, a sale of land must be in writing to be enforced in court. This written document serves as proof that both parties agreed to the sale.

However, the sale is still considered valid even without a written contract if it has already been fully or partly carried out. In such cases, a verbal agreement can still be legally binding, and witnesses may be allowed to testify to prove that the sale happened.

In this case, the sale was partially executed as Ocampo had partially paid for the land, taken possession of it, received the land title, and paid real property taxes. The SC thus admitted the testimonies of Ocampo and his witnesses, which proved the sale.

The SC, however, found that Ocampo’s payments to Batara’s brother Marcelo were ineffective because he was not authorized to accept them on behalf of his brother’s heirs.

Therefore, while the sale remains valid, Ocampo must pay the remaining balance of the purchase price, with interest, to Noblesa and Ernesto.

Read the full text of the Press Release at https://tinyurl.com/yeapyzcd.

Read the full text of the Decision at https://tinyurl.com/msxr7hsd.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.