G.R. No. L-55831 - People vs. Medrano

Petitioner Armando V. Ampil, acting as attorney for Angela Tuason de Perez, invoked his right of retaining lien over three certificates of title.
Respondents include Judge Corazon Julianno-Agrava, Antonio M. Perez, and Benigno Perez y Tuason.
The dispute centers on whether petitioner’s lien on the titles, acquired during his tenure as Angela’s counsel, should be enforced against those titles despite subsequent actions by Angela and the respondents.

The matter originated in Civil Case No. 34626, filed by respondents Antonio M. Perez and Benigno Perez y Tuason against Angela Tuason de Perez, seeking her placement under guardianship for alleged prodigality and maladministration of her properties.
On May 2, 1958, the parties submitted a compromise agreement in the civil case designed to settle the dispute, although Angela later denounced the agreement.
The Court of First Instance of Manila dismissed the civil case for lack of jurisdiction on September 30, 1958, a decision later affirmed by the Supreme Court in G.R. No. L-14874.
Respondents then filed Special Proceedings No. 03123 in November 1960, seeking approval of the compromise agreement. The domestic relations court dismissed the proceeding for lack of jurisdiction.

In G.R. No. L-19711, respondents Perezes appealed from the domestic court’s dismissal regarding the approval of the compromise agreement.
On November 17, 1966, the Supreme Court approved the compromise agreement as renewed by respondents, which included provisions transferring property rights.
Under the agreement, Angela ceded full ownership of specific properties (as evidenced by certificates T. C. T. Nos. 24927, 24928, and 34769) to her husband and son.

Termination of Attorney-Client Relationship and Assertion of the Retaining Lien

In November 1966, Angela terminated petitioner’s services without just or lawful cause and without paying his fees.
On February 16, 1967, petitioner asserted his retaining lien over the three titles in a letter to respondents’ counsel.
The lien was based on petitioner’s lawful possession of the titles attained during his professional engagement and on the rule that an attorney may retain documents until his fees are settled.

Respondents, having failed to secure the titles from petitioner, filed a motion for partial execution on February 22, 1967, disputing petitioner’s lien.
The domestic relations court issued an order on March 8, 1967, compelling petitioner to surrender the titles within five days.
Petitioner sought a writ of preliminary injunction from the Supreme Court to suspend the enforcement of that order, arguing that the attorney’s lien must be respected.

Petitioner leaned on the words of Rule 138, Section 37 of the Rules of Court, which guarantees an attorney a lien over his client’s funds, documents, and papers until his lawful fees are paid.
The decision referenced past cases (including Matute vs. Matute and Rustia vs. Abeto) where the sanctity of an attorney’s retaining lien was upheld.
Petitioner further distinguished between a retaining lien (a passive right to hold documents) and a charging lien (an active claim on a judgment for legal fees).

Whether petitioner’s attorney’s retaining lien over the three certificates of title is valid and enforceable despite Angela’s termination of his services.

Does the execution and later confirmation of the compromise agreement affect the validity of the retaining lien?
Can an attorney’s lien, attached during the attorney-client relationship, be enforced against titles later transferred pursuant to the compromise agreement?

Whether the respondent court acted with grave abuse of discretion by ordering the surrender of the titles to respondents rather than enforcing the lien against Angela.

Should the lien be enforced directly against the client (Angela) rather than her transferees (the respondents)?