Facts:

The case revolves around a petition for certiorari with mandamus filed by Maximo Calalang and Quirico T. Carag (petitioners), questioning the order issued by Judge Juan de Borja of the Court of First Instance of Bulacan on May 4, 1967, which denied the petitioners' motion to enforce an attorney’s lien for P11,726.22 against the National Rice and Corn Corporation (referred to as RCA). The background of this legal discourse stems from Civil Case No. 2395, where Enoc Santos and Magdalena Santos (the private respondents) initially filed for a total claim of P254,016.82 against RCA. This claim was successfully adjudicated in their favor, which resulted in Judge Borja ordering RCA to pay the Santos' P78,104.38, along with P7,810.43 as attorney's fees.

Maximo Calalang and Quirico T. Carag succeeded Atty. Virgilio V. David as counsel for the Santos, having been assigned the latter's rights under a contract of legal services. While the litigation was ongoing, petitioners

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Facts:

Parties and Proceedings

• Petitioners: Maximo Calalang and Quirico T. Carag, acting as assignees of Atty. Virgilio V. David.
• Respondents:
• Private respondents Enoc Santos and Magdalena Santos.
• Initially, the National Rice and Corn Corporation (RCA), later substituted by the National Grains Authority (NGA) per relevant resolutions.
• Underlying litigation:
• Civil Case No. 2395 in the Court of First Instance of Bulacan, where the plaintiffs (Santos) claimed a total of P254,016.82.
• A written contract of legal services was entered into on June 16, 1961, between the Santos and Atty. Virgilio V. David.
• Agreement provided that the lawyer (Atty. David) would receive 20% of the claim (separate from his regular fee) if the claim was awarded.
• Petitioners substituted for Atty. David by accepting an assignment of his rights and interests under the contract.

Litigation and Judgment Details

• After over three years of litigation in Civil Case No. 2395, Judge Juan de Borja rendered a decision favoring the Santos.
• Judgment awarded included:
• P78,104.38 for causes of action.
• P7,810.43 as attorney’s fees.
• Dismissal of the remaining causes of action and counterclaims.
• The case was then appealed before the Court of Appeals in CA-G.R. No. 36294-R.
• While the appeal was pending, the parties were negotiating an amicable settlement.

Filing and Recording of the Attorney’s Lien

• On September 21, 1966, petitioners wrote to RCA asserting their right to an attorney’s fee computed as 20% of the awarded amount, amounting to P15,620.98, in addition to the P7,810.43 awarded by the court.
• Petitioners recorded their attorney’s lien in the Court of Appeals on October 4, 1966.
• Notice of the attorney’s lien was:
• Furnished to private respondents Santos on October 7, 1966.
• Also served to the RCA (later NGA), with no opposition or objection filed by either party.
• The Court of Appeals, through its resolution on October 19, 1966, made the attorney’s lien a part of the record, certifying that a copy of the lien was to be sent to the lower court upon remand.

Subsequent Developments and Motions

• The amicable settlement between Santos and RCA precipitated the dismissal of the appeal in CA-G.R. No. 36294-R.
• Private respondents Santos subsequently received the judgment amount, and petitioners received a partial attorney’s fee payment of P11,705.21.
• Petitioners sent a demand letter for the balance of the attorney’s fee (P11,918.22).
• Upon non-compliance, petitioners filed a motion to enforce the attorney’s lien in Civil Case No. 2395.
• This filing was based on Section 37 of Rule 138 of the Rules of Court.
• Private respondents Santos did not oppose this motion.
• Respondent Judge Juan de Borja, in his order dated May 4, 1967, denied the motion on the principal ground that petitioners had allegedly failed to furnish the private respondents a copy of the attorney’s lien as required.
• Petitioners filed a motion for reconsideration on June 13, 1967, asserting that:
• Both Santos and RCA had been duly notified by service of the attorney’s lien.
• There could be no reduction of the fee by virtue of the amicable settlement due to the binding contract of legal services.
• The motion for reconsideration was denied without stated reasons.

Issue:

Compliance with Notice Requirement

• Whether petitioners satisfied the mandatory requirement of furnishing private respondents Santos with a copy of the attorney’s lien as required by Section 37 of Rule 138.

Impact of Failure to Object

• Whether the absence of any opposition from both private respondents Santos and RCA to the attorney’s lien filing rendered the matter res judicata, thereby entitling the petitioners to enforce their lien.

Effect of Amicable Settlement

• Whether the subsequent amicable settlement between Santos and RCA could lawfully modify or reduce the attorney’s fee agreed upon in the contract for legal services.

Reasonableness of the Attorney’s Fees

• Whether the attorney’s fees claimed by the petitioners, computed at 20% of the awarded amount, are justifiable in light of the quality and quantity of legal services rendered.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)