Plana Law Office

29/12/2025

We are OPEN today and tomorrow (Dec. 29 - 30, 2025) at 10am to 4pm and will resume usual office schedule/time on the 5th of January 2026. Thank you, dear clients.

26/12/2025

Season’s Greetings from Plana Law Office. Wishing our clients, friends and everyone a joyous and prosperous holiday season!

31/10/2025

PLO joins the “trick or treat” for the first time. 👻

21/10/2025

Good news, byaheros!

Good news, motorists!

You no longer need to have multiple RFID accounts for different tollways starting Tuesday, Oct. 21 with the newly introduced unified RFID system.

Read more at the link in the comments.

20/10/2025

This is an affirmation of your rights! FYI, especially to the concerned citizens of our home town-Sta. Catalina, Ilocos Sur, whose lands are now being expropriated for public use (coastal road).

The has reiterated that just compensation in land expropriation cases must be based on all relevant factors, not just market value.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division remanded to the Regional Trial Court (RTC) the case between the City Government of Pasay (Pasay LGU) and Arellano University (University) to reassess the amount of just compensation owed to the latter.

The University filed a complaint before the RTC in 2015, claiming that the Pasay LGU took its 805-sq. m. parcel of land in Barangay San Isidro and turned it into a public road, now known as Menlo Street, without going through proper expropriation proceedings or paying just compensation. The parties subsequently referred the matter to a board of commissioners composed of Pasay LGU officials.

The board used a base value of PHP200/sq. m. based on the 1978 General Revision of the City Assessor’s Office, then added 6% annual interest from 1978, the year the street was discovered, up to 2017, resulting in a value of PHP2,060/sq. m.

The University disagreed and proposed a total compensation of PHP 5,793,664.63, arguing that the interest should be based on the rates published by the Bangko Sentral ng Pilipinas.

The RTC adopted the board’s base value but applied a different interest rate, ordering Pasay LGU to pay PHP 161,000 plus 12% annual interest from 1978 to 2018.

The CA remanded the case to the RTC, ruling that the RTC relied solely on the 1978 assessment and ignored other relevant factors.

The SC upheld the CA, finding that the RTC’s decision was based on incomplete data.

Article III, Section 9 of the Constitution provides that private property cannot be taken for public use without just compensation. The SC emphasized that just compensation must be real, substantial, full, and ample, and that determining this amount is a matter for the courts to decide.

The SC clarified that although local government assessors provide appraisals, these are not controlling in expropriation cases. Such appraisals often cover broad areas and do not account for specific property differences. They rely on general descriptions and may be inaccurate. And while tax values can serve as a guideline, they cannot substitute for a comprehensive assessment of just compensation.

Thus, courts must use a “totality of circumstances” approach, considering all facts about the property’s condition, surroundings, existing improvements, and capabilities. These include the zonal valuation of the Bureau of Internal Revenue, acquisition cost, tax declarations, size, shape, location, and the current value of similar properties.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=153762

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=153692

Read the Separate Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/?p=153737

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

15/10/2025

17/09/2025

FYI❗️
Mas pinadaling pagkuha ng Birth, Marriage, Death Certificates, CENOMAR at CENODEATH mula sa PSA.

10/08/2025

Update: Application period is over.

Join our team. Apply na!

04/07/2025

Note: Public Officials.

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/.

03/06/2025

Due to unforeseen circumstances, we are closed today and will resume tomorrow. See you, dear clients.

08/05/2025

You can check your precinct number, polling place and voter registration status from this site. Vote wisely!

DATA PRIVACY NOTICE: Please be reminded that NO PERSONAL INFORMATION is being stored in the database. Your personal information are only being used to search and verify your voter registration status.

29/04/2025

To our dear clients,
we shall remain open today and tomorrow, April 30 & May 1, 2025. Thank you.