Facts:

• In August 1990, Ala Mambuay, Norma Maba, and Acur Macarampat filed civil suits against the National Power Corporation (NPC) in the Regional Trial Court of Lanao del Sur, Marawi City.
• The cases were consolidated due to similar causes of action related to NPC's refusal to compensate for damages to the plaintiffs' lands during the construction of the Marawi-Malabang Transmission Line.
• Plaintiffs were represented by Atty. Linang Mandangan and Atty. Mangontawar M. Gubat, who agreed on attorney's fees of P30,000.00 per case and P600.00 for each appearance.
• NPC failed to appear at the initial hearing, resulting in a default judgment on April 24, 1991, ordering NPC to pay damages and attorney's fees.
• NPC appealed the decision (CA-G.R. CV No. 33000) and later moved to dismiss the appeal, claiming a settlement with the plaintiffs.
• On January 24, 1996, the Court of Appeals annulled the default judgment and remanded the cases for a new trial.
• Atty. Gubat filed a Motion for Partial Summary Judgment for his attorney's fees, alleging a conspiracy between the plaintiffs and NPC to deprive him of his fees.
• The trial court granted the motion, ordering NPC and the plaintiffs to pay Atty. Gubat P96,000.00.
• NPC's motion for reconsideration was denied, leading to a petition for certiorari before the Court of Appeals, which ruled that the trial court committed grave abuse of discretion.
• The Supreme Court affirmed the Court of Appeals' decision.

Issue:

• (Unlock)

Ruling:

• Yes, the trial court erred in granting Atty. Gubat's Motion for Partial Summary Judgment.
• Yes, the Court of Appeals was correct in ruling ...(Unlock)

Ratio:

• The Supreme Court determined that Atty. Gubat's use of summary judgment was improper due to the existence of genuine issues of fact, particularly regarding bad faith, which required a full trial.
• Summary judgment is appropriate only when there are no genuine issues of material fact, and the movant is entitled to judgm...continue reading