Facts:

The case involves Atty. Augusto M. Aquino as the petitioner and Ma. Ala F. Domingo and Ma. Margarita Irene F. Domingo as the respondents. The events leading to this case began with Angel T. Domingo, the late father of the respondents, who owned a 262.2346-hectare rice land in Guimba, Nueva Ecija. This land was subject to the agrarian reform program under Presidential Decree No. 27 and was distributed to 193 farmer beneficiaries. The Land Bank of the Philippines (LBP) initially valued the land at P2,086,735.09, a figure that Angel contested. Consequently, he verbally engaged the legal services of Atty. Aquino, who filed a petition for the determination and payment of just compensation on July 31, 2002, claiming the land should be valued at P39,335,190.00.

On April 12, 2004, the Special Agrarian Court (SAC) determined the just compensation to be P15,223,050.91, a decision that was later affirmed by the Court of Appeals (CA) and upheld by the Supreme Court on February 4, 2008...

Facts:

Background of the Case and Agrarian Reform Context

• The case arises from a Petition for Review on Certiorari filed under Rule 45 against the April 13, 2009 and September 15, 2009 Orders of the Regional Trial Court (RTC), Branch 33, Guimba, Nueva Ecija, which served as the Special Agrarian Court (SAC) in AGR. Case No. 1221-G.
• The dispute centers on the award of attorney’s fees in a just compensation case. Petitioner Atty. Augusto M. Aquino, representing the estate of Angel T. Domingo who owned a 262.2346-hectare rice land covered by the agrarian reform program, claimed a contingent fee based on an increase in the just compensation award.

Determination of Just Compensation

• Angel T. Domingo’s land was subject to agrarian reform measures under Presidential Decree No. 27 and Executive Order No. 228, with the Land Bank of the Philippines (LBP) initially valuing the property at P2,086,735.09.
• Angel, disagreeing with this valuation, engaged petitioner’s legal services; on July 31, 2002, petitioner filed a petition before the SAC seeking a revised and higher valuation.
• The SAC on April 12, 2004, fixed the just compensation at P15,223,050.91, a figure that was later affirmed by the Court of Appeals (CA) and by this Court in its February 4, 2008 Decision in G.R. No. 168533.
• Subsequent to Angel's death, the respondents (his heirs) substituted, and the final computation of just compensation involved deducting previously paid amounts and directing LBP to pay the balance partly in cash and partly in bonds.

Petitioner's Claim for Attorney’s Fees and the Involved MOA

• On February 2, 2009, petitioner submitted a Manifestation with a Motion to Approve a Memorandum of Agreement (MOA) dated December 12, 2005.
• The MOA purportedly involved Angel and his brother Benjamin engaging the services of San Vicente and Gajitos in obtaining a revised (higher) valuation of the land.
• According to the MOA, in case of a valuation increase, San Vicente and Gajitos were to receive 35% of such increase, with Angel and Benjamin covering certain expenses.
• Petitioner also attached a Contract for Legal Services that specified a contingent attorney’s fee of 30% of the increase over the initial valuation.
• Based on these documents, petitioner sought to collect attorney’s fees commensurate with either the 35% commission for San Vicente and Gajitos or 30% as per the purported contingent fee agreement.

Proceedings Regarding the Award of Attorney’s Fees

• The SAC initially, in its Order dated April 13, 2009, adopted LBP’s computation and segregated 35% of the increased just compensation (P4,613,902.49) in petitioner’s favor.
• Later, in its September 15, 2009 Order, the SAC modified its ruling by awarding petitioner 30% contingent attorney’s fees (P3,954,773.57), reasoning that even in the absence of a formal written contract, petitioner was entitled to reasonable compensation for his legal services.
• The trial court’s resolution confirmed the grant of the 30% contingent fee and directed LBP to release the corresponding funds.

Respondents’ Appeal and Subsequent Motions

• Respondents opposed the award, arguing that:
• The MOA was allegedly false and that attorney’s fees had been previously settled.
• The SAC lacked jurisdiction to rule on a matter that should have been addressed with the settlement of Angel’s estate under the Comprehensive Agrarian Reform Program (CARP).
• Respondents timely filed a Notice of Appeal challenging the SAC’s orders canceling the set amounts and the manner in which attorney’s fees had been granted.
• Petitioner filed a Motion for Execution Pending Appeal on January 14, 2010, to enforce the September 15, 2009 SAC Order, which the SAC granted, thereby releasing the contested funds.
• Respondents then filed motions to reverse the execution order, which the CA denied in Resolutions dated August 9, 2010 and March 2, 2012.

Court of Appeals and Supreme Court Involvement

• In its January 9, 2015 Decision, the CA declared as void:
• The April 13, 2009 SAC Order insofar as it treated the Manifestation as a motion to charge attorney’s fees as a lien.
• The September 15, 2009 SAC Order insofar as it granted 30% contingent attorney’s fees to petitioner.
• The CA’s decision was based on the limitation of the SAC’s jurisdiction under relevant agrarian reform statutes and the proper channel for the claim for attorney’s fees.
• Petitioner filed the present petition on December 8, 2015 before this Court, contending that the prior CA Resolutions (which he claimed had attained finality) should have precluded the CA’s subsequent review and ruling on the issue.

Issue:

Whether the CA was precluded by its Resolutions dated August 9, 2010 and March 2, 2012 from addressing petitioner's claim for attorney’s fees in its subsequent January 9, 2015 Decision.

• Analysis of whether the prior Resolutions rendered the issue of attorney’s fees final and immune from further review.
• Determination of whether the dispute on attorney’s fees was distinct from the execution issue resolved in earlier CA Resolutions.

Whether the CA, in its January 9, 2015 Decision, correctly nullified the award of 30% contingent attorney’s fees in petitioner’s favor without precluding petitioner from filing a proper separate action to recover his fees.

• Examination of the legal basis for considering the award of attorney’s fees as subject to review even after earlier executions and rulings.
• Consideration of the appropriateness of applying the principle of quantum meruit in the absence of an express, written agreement.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)