It Er t l lH.t r OF 1 n, et al. vs. EFREN I o PLANA, et al.

DECISION -

•. 2 - accounts of petitioner, and in a letter dated February 29, 1972 respondent demanded from him the payment of the sum of ~762,847.68 as alleged defi- ciency income tax, surcharge and interest for the year 1966.

Not convinced of the legality of the assessment, petitioner protested the same with respon- dent on March 20, 1972 with the request that it be countermanded.

In a letter dated January 20, 1975, however, respondent requested petitioner to execute a waiver of the running of the prescriptive period of the statute of limitations up to June 30, 1980~ which the latter agreed up to March 14, 1975, but "' eventually was extended to February 28, 1978o Meanwhile, in a letter dated September 12, 1975 respondent suggested to petitioner the availment of the benefits of Letter of Instructions No. 308.

How-

ever, on December 22, 1975 petitioner offered respondent the payment of only the amount of P867o00 as 15% of his alleged legal liability in accordance with said Letter of Instructions No. 308 o On July 7, 1976, after study of the case, respon- . dent reduced the assessment of ~762,847o68 as deficiency income tax, inclusive of surcharge and interest for 1966 to P26,148.90 arrived at as follows:

- 3 - Net income per return o•ooooooo .. oooooooo•o• P 40,338o92

Add:

Unallowable deductions: 1 ..

Rental deposit~:-:-:-:-~:- . P 1,440.00 2~ Salaries and wages p~id 3o 4o 5o 6.

7o 8o 9.

lOo in connection with farming business o o ••••• o o Salaries paid to Mro Francisco Reyes ••o•o•o••• Salaries & wages accrued o Bonus payable ••• o o •••• o ••• Repairs and maintenance •• Transportation expense o• Light and water ooo•• o•o••o Taxes and licenses o . ...... Development cost written- 10,983.90 500.00 13,508.10 15,600o00 1,249.84 5,613.25 251.30 30.50 off ••••••o •••o• ooq oooooo•• 1,989.00 51J.l65o29 Net income per investigation o ...... " .. u ••• Less: Personal exemption ••ooooo <> •••••••• oo Net taxable income •o••oo•••• o<>u oo••o••• o•o• Income tax due thereon o••o•o .... o •• o .. .. .. .. o. Less: Amount paid oooooooo o••• oo •••o••••o• o• Balance of tax due •oo••o••• o••o••••o•• ooo•• Add: 18% maximum interest •••• o•o••• o••••••

TOTAL AMOUNT DUE AND COLLECTIBLE

p 91,504.21 ___ 3...._,_oqo.oo lP 88,504o21 ~ 31,282.00 9,122o00 p! 22,160.00 3,988.90 p 26,148.90 As regprds the offer of petitioner of 15% of P5,783.00, the amount claimed as due from him, representing compro- mise under Letter of Instructions No. ~08, respondent informed petitioner that inasmuch as the assessment of P26,148.90 was issued only on July 7, 1976, such assess- ment could not be the subject of a compromise under said Letter of Instructions since only delinquent accounts assessed on or before December 31, 1974 may be the sub- ject of a compromise thereundero Petitioner was there- fore urged to pay the said amount of P26,148o90, but if he is not agreeable .thereto, he could file a ~etition

- 4 - for review wit h this Court. Hence, the present appeal. In his answer to the petition _for review, respon- dent admits that the basis for the amended assessment was the disallowance of the following items , to wit: Rental deposit • o •••••• o • o .~ 1,440.00 Salaries and wages paid in connection with farming business • • • • • • • • • o ••• 10,983.90 Salaries paid to Mr. Francisco Reyes • 500.00

Salaries and Wages Accrued •

o •••• 13,508.10 Bonus Payable •••• o • • ••• a • 15,600o00 Repairs & Maintenance ••• o •• a o 1,249o84 Transportation expenses .• • ••••• 5,613.25

Light & Water

o •••••••• o • • 251.30 Taxes & Licenses • • • • • • • • • • • 30.50 Development Cost written off • • • • • 1,989.00 And respondent states by way of special and affirmative defense that "The disallowancesof the above-~entioned items were proper since in an administrative hearing conducted on March 21, 1973, petitioner f a iled to sub- stantiate or justify the aforementioned deductions and/or exclusions in its income tax return for 1966." (Par. 6, Answer, Po 33, CTA records.) . So that if peti- tioner was able to substantiate or justify any or all the above deductions and/or exclusions in the hearing before this Court , it follows that the assessment under review s hould be cancelled or modified as the case may beo Has petit ioner been able to substantiate by adequate evidence the above -~ention ed deductions which he claimed in his 1966 income tax return? ,, ~ r ~ ~iU

- 5 - At the outset, it should be stated that tax assessments are presumed to be cor~ect unless the contrary is shown, and the burden of proof rests upon the taxpayer to overcome this presumption. The deter- mination, however, of a deficiency by the Government i s only prima facie correct. (Gutierrez vs o Collector of Internal Revenue, L-~9537, May 20, 1967, 14 SCRA 33; Tan Guan vs . Court of Tax Appeals, L-~3676, April 27, 1967, 19 SCRA 903; Republic vs o Philippine Rabbit Bus· Lines, Inc., L-26862, March 30, 1970, 32 SCRA 211.) In light of t his legal presumption and the special and affirmative defense of respondent that the above-~entioned items were disallowed because in the administrative hearing conducted by his office, petitioner failed to substantiate or justify the afore-mentioned deductions and/or exclus ions, we will now proc~ed to examine the evidence of t he parties presented not only in the hearing befor e the appellate division of the Bureau of Internal Revenue but more particularly before this Court and determine whether petitioner has properly substantiated his claimed deductions in his 1966 income tax return t o be entitled to deduct the same.

After

all the hearing before this Court partakes of a trial de ~ and the Court is authorized to receive evidence, summon witnesses, and give both parties, the Government and the taxpayer, opportunity to present and argue their

- .6 - sides, so that the true and correct amount of the tax to be collected may be determined ~nd decided.

(Collec-

tor of Internal Revenue vs. Batangas Transportation Company & Laguna-~ayabas Bus Company, L-9692, January 6, 1958, 102 Phil . 822.)

We will now discuss the disallowed deductions in seriatim in the order listed by respondent in his decision appealed from and ascertain whether or not petitioner is entitled to his claimed deductions. For better understanding of the case and easier appraisal of the evidence presented, attached hereto and made an integral part of this decision are Annexes which consist of lists of the exhibits proffered by petitioner to substantiate his claimed deductions to which refe- renee will be made in the discussion of each item. 1.

Rental Deposits -

~1,440.00 Respondent considered as undeclared income these rental deposits in the amount of ~1,440o00 reflected in the books of petitioner as of December 31, 1966, ~lleging that they are not liabilities as contended by petitioner because it is arnual practice in the leasing business to require the tenant a deposit equi- valent to two (2) ~onths at the time of occupancy; hence, they should be treated as income in the year they were received.

As authority thereof, respondent cites Merten'~ Law of Federal Income Taxation to the ') r-; 0

N

4 !_)

- 7 - effect that "rents received on either cash or accrual basis by taxpayers under a claim of right without res- trictions, contractual or otherwise, constitute income in the year of receipt." (Vol. 2, Chapter 12, p. 86, par. 12.30; Respondent'~ memorandum, p. 90, CTA records.) On the other hand, petitioner maintains that it is customary business practice to require the tenant to put up a deposit equivalent to one or two months as security for unpaid rentals or any damage on the leased property during the tenant's occupancy. This rental deposit is set up in the books of accounts as an obli- gation to the tenants.

When he vacates the premises and he does not have any rentals in arrears, this deposit is returned to himo If he leaves the leased property with an unpaid rental , the deposit is applied and set up as rental incomeo (t.s.n., p. 6, hearing on August 31, 1977.) . To prove this, petitioner pre- sented Exhibits "B" and "B-1.'' to "B-8", consisting of the rental deposit schedule and analysis , and the supporting official receipts and cash vouchers showing the subsequent refund or application of these deposits j to rental income.

(t.s.n., pp. 42-4.9, hearing on

J

September 31, 1977; Annex 1 of Decision.). No proof was presented by respondent to controvert or dispute these evidence of petiti oner.

- 8 - Judging f rom the foregoing, it is qui t e apparent that the nature of the disputed re~tal deposits is more of a security fo~ the lessee'~ performance than a pre-payment of rent, t here being no written agreement regarding the disposition of these rental deposits. (p. 144, Vol. II, BIR records~ pp. 400-~01, Vol. II, BIR records.)

In the case of rental deposits, it has been held that:

"If, however, payment is made t~ secure the lessee'~ per f ormance under the lease it is not taxable income even though the fund is deposited with the lessor instead of in escrow and the lessor has temporary use of the money. Since in some instances the payment s e rve s as security for the lessee'~ perfor- mance and, in addition, maybe applied to rent, it fre- quently becomes necessary to determine whether the deposit was primarily a security payment or a prepayment of rent."

(Merten's. Law of Federal Income Taxati.on, par. 12.30, vol. 2, chapter 12, p. 87-~8.) Clearly, therefore, the rental deposits in the amount of ~1,440.00 do not constitute taxable income for the year 1966.

2.

S alar ~ es And Wages Paid In

Connection With Farming

Busine ss - ~10,983.90 The salaries and wages in the amount of ~10,983.90 paid by petitioner to his employees and farmhands at

- 9 - his Liwayway Plantation at Mauban, Quezon Province, were disallowed by respondent because they were not substantiated.

Respondent'~ examiner'~ main reason for the disallowance was that no payroll sheets or other documents or papers were presented.for verifi- cation to prove that the total amount of Pll,914.90 (reduced to Pl0,983.90) .was actually paid and received by the employees and/or laborers of said plantation. (Examiner'~ report, PPo 130-~33, Vol. II, BIR records.) During the hearing of the case before this Court, how- ever, petitioner introduced as evidence the cash vouchers (Exhibits ''C",

"C-~" to "C-~" and "C-4" to

"C-~8") ~ith signed payrolls and receipts attached thereto to justify the deduction of the above wages. (See Annex 2 of Decision.) Having met the condition required by respondent for the allowance of this claimed deduction, it follows that petitioner is entitled to deduct from his gross income the above salaries and wages in the amount of Pl0,983.90o 3o Salaries Paid To Mr o F. Reyes - P500.00 Payment of this expense in the amount of P500.00 was made per Cash Voucher No. 3629 (Exhibit "F") ~ated April 13, 1966 by PBTC Check Noo 786839 to taxpayer Augusto L. Guanzon to reimburse him for the amount he paid to Atty. Francisco Reyes for services allegedly

DECISION -

CTA CASE NO . 2821 - 10 - rendered to Ao L. Guanzon Real Estateo Upon verifi- cation by respondent'~ examiner, P~TC Check No. 786839 was found to be payable to Augusto L. Guanzon a nd deposited in h is account. {p. 130, Vol. II , BIR records.) , There were no supporting papers showing that payme nt was previously made to Attyo Francisco Reyes and the natur e , extent and value of the service s he was being compensated for .

Petit ioner having failed to justify and substan- tiate the d eductibility of this expense, the same should be disallowed.

4.

Salaries a nd Wages Accrue d - ~13,508.10

Su

Bonus Pa~able - ~15,600 .00 Both the accrued salaries and wages in the amount o f Pl3, 508.10 and the bonus payable in the sum of Pl5,600.00 were disallowed by respondent for the same reason; namely , they were entered in the books of acc ounts o£ petitioner as expense accounts and claimed as deductions fr om gross income in 1966 without any supporting journal vouchers explaining the nature of said e xpense.

(p. 129, Vol o II, BIR records .) And t hat no doc uments were ever presented to substantiate tax payer'~ claim of the above items as deductions from gross income despite verbal as well as written requests made to th is effect.

( Respondent'~ memorandum, p. 92, q .,_,. ') 1-W u 1-....1

DECIS I 0N -

CTA CASE NO . 28 21 - 11 - C'I'A records. )

It should be stated that when the case was heard before this Court, petitioner, to establish the fact that these accruals were actually paid in the succeed- i ng years , presented the cash vouchers (see Annex 3 of Decision; Exhibits "D", "D-1" to "D-1_4" and Exhibits "E", "E-1" to "E-6_") .issued in payment of the disputed accrued salaries and bonuses , s howing the payees and the corresponding explanation for each disbursement. (t.s.n., pp. 11-~1 , hearing on August 31, 1977.) . Except for Cash Voucher No . 3941 in payment of an accrued salar y f or ~270.00 which was not submitted for verificat i on, all the other vouchers were duly signed and r eceipt ed f or.

Since respondent did not impugn or ' controve r t the correctnes s of petitione r '~ supporting documents , re s pond e nt'~ disallowance of these disputed items, with the exception of the above-stated ~270 . 00, can not be sustained .

6.

~epairs And Ma inte- nance - Pl ,249 .84 Of the amount of ~2,329 . 84 representing repairs and mainte nance expenses disallowed by respondent's. examiner in the original investigation , ~1 , 180 .00 wa s considered as allowable deduction in the reinvestigation of this c a se~ The remaining ~1 , 24 9. 84 was disallowed by the exami ner because it was not supported with '> :_;. f") ; ...., (..._ ) -...)

- 12 - receipts and invoices.

(p. 396, Vol. III, BIR records.) A re-examination of the twenty-seven (27) ~ash vouchers presented by petitioner showing payments of these repairs will disclose that only ten (10) youchers are not supported with receipts nor signed by the payee~ Most of the ten (10) youchers are reimbursements of wages and are of insignificant amounts, the total of which adds up to only a little over ~200.00.

(See Annex

4 of Decision; Exhibits "G", "G-1." to "G-26".). It is of common knowledge that for minimal repairs, evidencing payments to laborers are generally overlooked. And since the unsupported payments for repairs are not substantial nor unreasonable, the total amount of ~1,249.80 may be allowed. 7 .

Transportation Ex-

pense - ~5,613.25 Transportation expenses in the amount of P5,613.25 were disallowed by respondent for lack of evidence showing that they were incurred and spent in connection with taxpayer'~ business. (Po 396, Vol. III, BIR recordso) The breakdown of the transportation expenses pre- pared by petitioner (petitioner'~ memorandum, p. 53, CTA records) .shows that it is composed mainly of three items, namely:

transportation and meal allowances given to Mrs. Dolores A. Guanzon, assistant manager and cashier, covered by General Journal No. 21 in the amount of ' ) <;:. . ~

N

~-"" . .l

- 13 - ~1,402.05; expenses of ~4 , 200 . 00 per General Journal No. 24,and transportation expenses . paid to personnel per petty cash vouchers totalling ~11 . 20 .

(Exhibits

"H" & "H-1." to "H-3."; Annex 5 of Decision.) The details of General Journal No. 21 are reflected in the cash vouchers presented as Exhibits "H-4" to "H-8." (see Annex 5 of Decision) .which are reimbursements made to Mrs. Dolores A. Guanzon in 1967 for transport- . ation and meal expenses incurred in inspecting ricelands at Lubao, Minalin and Macabebe , Pampanga, from June to December , 1966.

However, aside from the Liwayway farms in Mauban, Quezon Province, it doe ~ not appear in the records that the ricelands at Lubao, Minalin and Macabebe, Pampanga, are income-producingo It is incumbent upon petitioner to establish that the expenses in these inspection trips were incurred in the pursuit of his t~ade or business; otherwise , said allowances can not be allowed as deduction . (Sec .

30(a5~ National Inter-

nal Revenue Code . )

~As explained ~y counsel for petitioner, the expenses in the amount of ~4,200o00 covered by General Journal Noo 24, which was not presented as evidence, consisted of electric bills paid to Gaudencio Manalac Electric for street lights at Florida Homesite Subdivision . (Petitioner's. memorandum, p . 53, CTA records o) .Clearly , said payments are not transportation and can not there-

- 14 - f ore be deductible as such. Of the three items enumerated, only those for transportation expenses paid to personnel in the total amount of ~ll o 20 should be allowed as deductible expenses since these were substantiated by petty cash vouchers and signed by the payeeso

(Exhibits "H" &

"H-1" to "H-3."; Annex 5 of Decision.) 8.

Light And Water -

~251.30 The electr ical cons umption for December, 1965, at Florida Housing Subdivision amounting to ~25l o 30 paid per Cash Voucher No . 3605 (Exhibit "H-9."; Annex 5 of Decision) _on March 17, 1966 was correctly disallowed by respondent as it should not have been taken up as an ·expense in 1966 , but should have been accrued in 1965, petitioner being on the accrual basis. 9.

Taxes And Licenses -

~30.50 Petitioner claimed as deduction in 1966, taxes and licenses i n the amount of ~38 o 00 which consists of ~30.00 for occupation fees for the Liwayway Mining Claim for the years 1963, 1964, 1965 and 1966 and an additional charge of ~8.00.

On the ground that the fees for the years 1963, 1964 and 1965 amounting to ~22.50 should have been accrued and deducted in said years and that the addi- tional ~8.00 charge was not evidenced by any receipt, q ~. G tV ._.,

- 15 - bill or invoice, respondent disallowed the sum of ~30.50.

(Examiner'~ report, p . 119, Vol. II, BIR records.)

No evidence or explanation was offered by petitioner to refute this , hence, the disallowance should be sustained .

10.

Development Cost Written

Off -

~1,989 . 00 The development cost of petitioner's coffee, black pepper and cacao project, set up as capital expenditure prior to 1966, was written off as an expense in 1966, allegedly because it was found to be a failure .

(Peti-

tioner'~ memorandum , Po 55 , CTA records.) Aside from this bare statement , no adequate evidence was furnished by petitioner at any time during the administrative and court hearings of this case to prove his claim . For . .

failure to substantiate or justify this claimed deduc- tion, the same should be disallowed.

Prescription

Not much need be said on petitioner ' ~ point that the r i ght of respondent to assess the tax in question has already prescribed. The situation here presented would not create prescription because, as stated earlier, petitioner signed a waiver of the statute of limitations whereby he agreed in writing to the assessment of his • deficiency income tax for 1966 up to February 28, 1978o The final assessment was made by respondent on July 7, q \.:

7• ,,...,., :,;

- 16 - 1976 which i s within the period agreed upon.

Computation

For all the f oregoing, the computation of the deficiency income tax liability of petitioner for the year 1966 is as follows: Net income per return •••• o • • • P40,338 o92

Add:

Unallowable deductions : Salaries paid to Mr •• F. Reyes ••••••• ~ 500.00 Salaries and wages accrued • • o • o • o Transportat ion expenses Light and water • • • Taxes and licenses • o Development cost 270 o00 5,602.05 251.30 30.50 written off o • 1,989e00 8,64.2. 85 Net income per decision ••• P48,981.77 Less: Personal exemption •• o 3,000.00 Net taxable income • o ••• o • ~45,98l o 77 Income tax due thereon • • • • • Pl2,473.00 Less: Amount paid • o •• o 9,122.00 Balance of tax due o • • • • • • ~ 3,351.00 Add: 18% maximum interest • • • 603.18 Total amount due and collectible ~ 3 u954ol8 Accordingly, petitioner Augusto Lo Guanzon is here- by ordered to pay the amount of ~3,954.18 to respondent Commissioner of Internal Re venue as deficiency income tax and interest for the year 1966, plus the surcharges and interest which have accrued thereon incident to delinquency, pursuant to Section 5l(e) of the National Internal Revenue Code, as amended.

WHEREFORE, the decision appealed from is modified as indicated in the above opinion of the Court. With

- 17 - costs.

~B:J

Presiding Judge

WE CONCUR:

-

• ROAQUIN

ssociate Judge q • ... · () 1-V u .. _

ANNEX 1

1.

Rental Deposits - j1,440.00

Exhibit

Date

c.v. or

Tenant

Particulars

Amount

Findings

No .

o.R. No .

-- - -- - ------ - - - - - - - - - ·- - - - -------

B-3

7-1-65 O.R.

Perfex Engi-

Deposit for

jl 420.00 Applied to 3668 neering and bodega rent income l1achinery per CoV. 4769 (Exh. B-8)

B- 4

7-S-66

o.R.

Pablo s. Luna Deposit for 420 . 00 Applied t.o 4113

Enterprises

bodega

Rodolfo Luna's

rent per O.R~ 5229 dated 5-31-79,

(Exho B-7)

B-5

5-11-66 o .R.

Andres

Deposit for Apt.

200 . 00 Applied to ren- 4053

Castillo

Noo 744, 7th tal income for

Avenue

Gregorio Gonzales

per G.J. Noo 15 dated 12-31-67 (Exh . B-2) Peti- tioner' s exhibits.

B-6

8-25-66 o.R.

Jemm Enter-

Deposit for 640-

400o00 Applied to ren- 4165 prises

642 Magdalena

tal income per

Extension

G.J . Noo 15 dated

12-3 1-67 (Exho

B-2) Petitioner's

exhib-its o

T 0 T A L

!!l~~~Q2.QQ -~--:---- - -

B-7

5-31-69

OoRo

Rodolfo Luna March to May,

(See Exhibit B-4)

5229 1969 rent paid for Bodega A less deposit per O.R.

4113 ~:!!~~~~~~

B- 8

9-4-69 o.R. Perfex Engi- Refund of bal-

(See Exhibit B-3)

4769 neering and ance of rental

Machinery

deposit jl 378.51 ;::==;:===== q e n ,. • !(.J \ ••

ANNEX 2

2. Salaries and Wages on Farming

Business

Exhibit

Noe

C=]

C-2

C=27

C=4

C-28

C-5

C-6

C-23

C-7

Date

1-20-66 2-11-66 2-23-66 3-11-65 3-25-66 3-25-66 4-13-66 4-25-66 4~25-66 5~17-66 5~31-66 6-9-66 6-25-66 7-25-66 7~25-66 8= 1-66 8-11-66 8-11-06 8-24-66 9=2-65 9-14~66 9~30-66 10-15-66 11-8-66 11-15-66 11-15-66 11=23~-66 NOTE ;

Voucher

N Oe

3531 3568 35890 35356 3612 3613 3630 3646 3647 3669 3631 3692 3705 3722 3723 3735 3745 3747 3759 3774 3779 3798 3112 3535 3839 3840 3851 B11,914.90 reduced to P10,983.90

PARTICULARS Amount

Payroll of 7 farmhands, 1 supervisor, | super- # 473.00 intendent at Hacienda Liwayway, Mauban, Quezon for Dec. 16-31, 1965 Payroll for Liwayway Farm for Jan. 1-15, 1966 448.50 Payroll for Liwayway Farm for Jan. 15-31, 1966 483.50 Payroll for Liwayway Farm for Feb. 1-15, 1966 483.50 Payroll for Liwayway Farm for Feb. 16-28,1966 434 650 Payroll for Liwayway Farm for Mar. 1-15, 1966 483.50 James Manis, Bangcua Tuba Penguet, Mt. Pro- vince for services rendered for March 1966 135.00 Payroll for Liwayway Farm for Mar. 16-31,1966 508.00 Payroll for Liwayway Farm for Apr. 1-15, 1966 434.50 James Manis, Bangcua Tuba, Services rendered for April, 1966 135.00 Payroll for Liwayway Farm for Apr. 16-30, 1966 473.00 Payroll for Liwayway Farm for May 1-15, 1966 459.00 Payroll for Liwayway Farm for May 16-31, 1966 508.00 Payroll for Liwayway Farm for June 1-15, 1966 483.50 Payroll for Liwayway Farm for June 16-30,1966 483.50 James Manis, services rendered for June, 1966 135.00 Payroll for Liwayway Farm for July 1-15, 1966 459.00 James Manis, services rendered for July, 1966 135.00 Payroll for Liwayway Farm for July 16-31,1966 483.50 Payroll for Liwayway Farm for Aug. 1-15, 1966 442.50 Janes Manis, services rendered for Aug., 1966 135.00 Payroll for Liwayway Farm for Aug. 16-31,1966 508.00 Payroll for Liwayway Farm for Sept. 1-15, 1966 483.50 Payroll for Liwayway Farm for Sept.15-30, 1966 460.59 Payroll for Liwayway Farm for Oct. 1-15, 1966 3910.00 Payroll for Liwayway Farm for Ccte 16-31, 1966 507.50 James Manis, services rendered for Sept. and Oct., 1966 270.00 Payroll for Liwayway Farm for Nov. 1-15, 1966 466.00 Correct Total #11,421,50 om All payrolls were signed by the payees.

=SSssaae sw

4.

Salar i es and Wages Accrued ~13,508.10 (Taken up as expenses in 1966)

Exhibit

Cash

No.

Voucher

No .

Date

Paid

PARTICULARS

ANNEX 3

Rose-

Dolores Antonio Others

Harie

Guanzon Guanzon

Guanzon

-. - - - - - - - - - - - - - - - - -

D

3967 2-23-67 Assistant to the Gen. l1anager , Administrator, Comptroller of A.L.Guanzon Real Estate, Agriculturc & Florida Homesite Subdv. Salary for Jan. to Mar. , 1965 ~1,800.00

D-1

3970 2-23-67 Cashier-Bookkeeper of A.L. Guanzon Real Est. Salary for Harch to July , 1966 @ 1!450.00 a month 1!2,250.00

D-2

4055 5-17-67 Cashier-Bookkeeper of A.L. Guanzon Real Est. Salary for August to December, 1966 2' 250.00

D-3

4064 5-19-67 Assistant to the Gen. Manager of Real Est. &

Administrator of Liwayway

Cacao , Black Pepper &

Banana Plantation for

Sept. 16 to Oct.15, 1966 ilOO .OO

D-4

D-5

4079 6-9-67 Asst. to the Gen.Hanager of Real Est. & Adminis- trator of Liwayway Cacao,

Black Pepper & Banana

Plantation for Oct. 16 to Nov. 15, 1966

L•095

7-10-67 Asst. to the Gen. Manager of Real Est. & Adminis- trator of Liwayway Cacao,

Black Pepper and Banana

Plantation for Nov. 16 to Deco 15, 1966

D-6

4122 7-28-67 Asst . to the Gen. l1anager of Real Est. & Adminis- trator of Liwayway Cacao,

Black Pepper & Banana

Plantation for Dec. 16 to 31, 1966 () q ') ""- c.i r<.tl 100.00 100.00 so.oo

Exhibit Cash

Date

No.

Voucher

Paid

No .

PARTICULARS

Rose-

11arie

Guanzon

D-7

4267 12- 5-67 Salary of R. Guanzon for April to July, 1966 @ i600.00/mo.

i2,400.00

D-8

4268

12-16-67 Salary of Ro Guanzon

for August, 1966

D-9

3898 1-4-67 Flora Ricafort services

D-10

D-11

D-12

rendered to A.L. Guanzon for 1966 3914 1-17-67 Farmhands (1 superinten- dent, 1 field supervisor, 7 farmhands) payroll for Dec. 1-15, 1966 3934 2-7-67 Farmhands (1 superinten- dent, 1 field supervisor, 7 farmhands) payroll for December 16-31, 1966 3920 1-28-67 Atty. Pedro 11arbella, for services rendered

D-13

4395 4-17-68 Salary of R. Guanzon for September, October and 600.00 November, 1966 i1,800 . 00

D-14

4396

4-18-68 Salary of Ro Guanzon for

December, 1966 600.00 3941 Not presented by peti- ANNEX 3 continued

Dolores Antonio Others

Guanzon Guanzon

• i100.00 483.50 504.50 100.00 tioner 270o00

T 0 TAL

i7,200.00 ~!!._;500~00 i350.00i1 , 458.00 5.

Bonus Payable

E

E-1

E-2

E-3

4090 6-30-67 Part payment of bonus to A. Guanzon 4265 12-5-67 Full payment of 1966 bonus to 'A. Guanzon 4290 12-29-67 Full payment of 1966 bonus to D. Guanzon 4266 12-5-67 Part payment of 1966 bonus to D. Guanzon ~5,600 . 00 1,600.00 i!2,000.00 1,600.00

E-4

4335 2-19-68 Part payment of 1966

E-5

E-6

bonus to R. Guanzon i 800. 00 4340 2-24-68 - do - 3,500.00 4341 2-28-68 Full payment of 1966 bonus to R. Guanzon

T 0 T A L

i soo.oo i4,800 . 00 i!3,600.00 i7,200.00

NOTE:

All vouchers were signed by the payeeso ---

ANNEX 4

DECISION -

CTA CASE NO. 282 1 6.

Repairs and Haint0.nance

Exhibit

No.

Date

Cash

Voucher

No.

Payee

PARTICULARS

Amount

· Findings

G

G-1

G-2

1-5-66 3507

Caloocan

Champion

Lumber

Plumbi ng materials' for repair at 123 Floren- cio Street i 1-6-66 3508 J.B. Reno Electrical materials Enterpri- for r epair at 123 ses

Florencio Street

1-15-66 PCV

Lanuza &

436 Co.

Materi als for repair at 128 Stao Lucia St.

G-3

1-25-55 3542 A. Guanzon For r eimbursement for payment made for repair of water pipes at 1239

Lorcucia Street

G- 4

G-5

G-6

G-7

G- 8

2-2-66

PCV

Rosauro

Payment of carpenters 457

Pineda

for r epair in 7t h Ave. 2-23-66 2-26-66 2-26-66

PCV

472

PCV

475 4-30-66 cv 3654 Domi nador Apartment

Balangit

Pedro

Hac don by D.

Guanzon

D.Guanzon - do -

Reimbursement for

elect rical materials for r epair at 123

Floreneio Street

- do - - do - A.Guanzon Reimbursement for electrical repairs at 744 A.& B.

G-9

4-25-66

PCV

G-10

517 A.Guanzon Reimbursement for repairs as per attached invoice 5-27-66

PCV

Glomera

547 Expenses for cleaning 74.00 Receipt attached 180.04 - do - 36.00 - do - 50.00 Reimbursement 10.00 Signed by payee 15.50 Reimbursement s.oo - do - . 15.00 - do - 82.00 - do - 52.85 Invoice attached 19.00 Receipt attached

G- 1 1

6- 11-66

PCV

D.Guanzon Reimbursement for repairs 558

at Florida Blanca Home-

site and Inspection trip 24.60 Expenses itemized q f) '1 "" .. ' ANNEX 4 continued

Exhibit Date

Cash

Payee

PARTICULARS

Amount

Findings

No.

Voucher

No.

- --- - - - - - - - - - - - - - - - -

G-12

3-5-66

PCV

Repairmen General cleaning and 482 repair of typewriters i! 5.00 Signed by payee

G-13

6-28-66 cv A.Tibayan Repainting of 640-642 3728 Rizal Avenue Ext.

400o00 Signed by payee

G-14

8-23-66 PCV

So Santos Advance for 5 pieces 627 G.I. Gutters 10.00 Signed by payee

G-15

9-1-66

PCV

R.Guanzon Reimbursement for ser- 642 vices rendered on electrical installation at 7th Avenue 10.00

Reimbursement

G-16

10-7-66

PCV

l'iacdon Repair of aircon 30o00 Signed by payee 682

G-17

10-10-66 PCV

RoGuanzon Reimbursement for repair 685 of aircon at 123 Floren- cio Street 15.75

Reimbursement

G-18

10-19-66 PCV

D.Guanzon Reimbursement for repair 006 of electrical connections

at 123 Florencio Street

23.20 Reimbursement

G-19

12-7-66 cv Mac don Repair and cleaning of 3869 jetmatic pump at Florida Homesite Subdv.

50.00 Signed by payee

G-20

12-2-66 cv D.Gu.anzon Cost of bamboo poles and Receipt attached & 3877 rope 21.90 Signed by payee

G-21

12-21-66 cv Abellera Labor for repainting 3887 Guanzon Lime Bldg.

42.00 See Exh. "G-22"

G-22

12-27-66 3888 R.Guanzon Paints per invoices (not attached 51.00 Receipt not attached

G-23

12-15-66

PCV

Abellera Advances for repainting 092 Guanzon Bldg.

5.00 Signed by payee

G-24

12-16-66

PCV

Songco

Jetmatic pump install- 093 ation 5.00 Signed by payee

·G-25

5-20-66

PCV

DoBalangit Extra labor (painting 540 R. Pineda of 7th Ave. Apt. on S~nday 12.00 Reimbursement

G-26

8-31-66 639 A.Guanzon Reimbursement for service rendered by Mejia 2.00 Reimbursement

T 0 TAL

I

i!l~249.84 . ;::=-===;::== r

ANNEX 5

7.

Trans£ortation and Travelling P5,613.25

Exhibit Date

No.

Cash

Voucher

Noo

-----

H

2-1~66

PCV

Payee

PARTICULARS

Transpor tation for long

Amount

Findings

456

Eddie

Song co distance call ~ 3.50 Signed by payee

H-1

2-11-66

H-2

9-1-66

H-3

12-!9-66

PCV

460

PCV

6/;1 095 s igned butTransportation and meal illegible to bring price list - do - Transportati on from Florida Homesite Subdv.

Pineda

Transportation for pur- chases from drugstore

T 0 T A L

G-J Noe 21 covering the follovting Cash Vouchers 4.00 3.50 o20 ~ 11 . 20 :::~;:::====

H-4

1- 4-67 3897 A. Guanzon Reimbursement for trans- portation and meals to i nspect ricelands at Lubao, Minalin , Macabebe , Pampanga Signed by payee Signed by payee Signed by payee for June, 1966 ~200.00 Signed by payee

H-5

1-31-67 3922 - do - - do - for July and part of Aug .• , 1966 300.00

H-6

2-3-67 3927 - do - - do - for August & Sept . 1966 300.00

H-7

2-7-67 3942 - do - - do - for Oct o & part: of Nov.

1966 300.00

H- 8

2-22-67 3966 - do :- - do - for Oct., Nov.

& Dec. 1966 300.00

T 0 TAL

~='=~~~~~~~ G-J No. 24 According t.o petitioner, the item covered consists of electric bills paid to Gaudencio Manalac" Electric for street lights at Florida Homesite Signed by payee Signed by payee Signed by payee Signed by payee Subdv.

~4,200.00 Not presented

H-9

3-17-66 cv 3605 G.s. Mana-For electricity con- lac sumed at FHS Dec.'65

Electric

and

T 0 T A L

For electricity con- sumed at FHS Jan. 169 251.30 For Dec. '65 no receipt attached 251.30 Receipts for Jan. '66 attached