Facts:

In August 1990, plaintiffs Ala Mambuay, Norma Maba, and Acur Macarampat filed separate civil suits for damages against the National Power Corporation (NPC) in the Regional Trial Court of Lanao del Sur, Marawi City, under Civil Case Nos. 294-90, 295-90, and 296-90. The plaintiffs were represented by Atty. Linang Mandangan and Atty. Mangontawar M. Gubat, who had agreed on attorney's fees of P30,000.00 for each case and P600.00 for every appearance. The complaints were consolidated due to the similarity of the causes of action, which stemmed from NPC's refusal to compensate the plaintiffs for improvements on their lands that were damaged during the construction of the Marawi-Malabang Transmission Line. During the initial hearing, NPC failed to appear, leading to a default judgment against it on April 24, 1991, where the court ordered NPC to pay the plaintiffs various amounts for damages and attorney's fees.

NPC appealed the decision, which was docketed as CA-G.R. C...

Facts:

Background of the Case

• In August 1990, plaintiffs Ala Mambuay, Norma Maba, and Acur Macarampat filed separate civil suits for damages against the National Power Corporation (NPC) before the Regional Trial Court (RTC) of Lanao del Sur in Marawi City. The cases were docketed as Civil Case Nos. 294-90, 295-90, and 296-90.
• The plaintiffs were represented by Atty. Linang Mandangan and petitioner Atty. Mangontawar M. Gubat. The agreed attorney's fees were P30,000.00 per case and P600.00 for every appearance. Atty. Gubat signed the complaints on behalf of himself and Atty. Mandangan.

Consolidation of Cases

• The three cases were consolidated due to the similarity of the plaintiffs' causes of action. The claims arose from NPC's refusal to pay for the cost of improvements on the plaintiffs' lands, which were destroyed during the construction of the Marawi-Malabang Transmission Line.

Default Judgment

• During the initial hearing, NPC and its counsel failed to appear, leading to NPC being declared in default. Despite NPC's plea to lift the default order, the RTC rendered a decision on April 24, 1991, awarding damages to the plaintiffs, including attorney's fees.

Appeal and Compromise Agreement

• NPC appealed the decision to the Court of Appeals (CA). During the pendency of the appeal, Atty. Gubat filed a Notice of Charging Lien for his attorney's fees.
• On August 19, 1992, NPC moved to dismiss its appeal, claiming that a settlement had been reached with the plaintiffs. The plaintiffs signed acknowledgment receipts for the amounts received, but Atty. Gubat was not informed of the settlement.

CA Decision

• On January 24, 1996, the CA annulled and set aside the RTC's decision and remanded the case for a new trial, ignoring the compromise agreement.

Motion for Partial Summary Judgment

• After the case was remanded, Atty. Gubat filed a Motion for Partial Summary Judgment for his attorney's fees, alleging that the plaintiffs and NPC conspired to deprive him of his fees. The RTC granted his motion, ordering NPC and the plaintiffs to pay Atty. Gubat P96,000.00.

CA Reversal

• NPC filed a Petition for Certiorari before the CA, which reversed the RTC's decision, stating that Atty. Gubat could not enforce a lien based on a vacated decision. The CA ruled that the RTC committed grave abuse of discretion.

Issue:

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Ruling:

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Ratio:

1. Wrong Mode of Appeal: A petition for certiorari under Rule 65 is not the proper remedy when an appeal under Rule 45 is available. Atty. Gubat's petition was filed out of time, and the Court could not treat it as a Rule 45 petition due to procedural lapses.
2. Impropriety of Summary Judgment: Summary judgment is only proper when there are no genuine issues of fact. The issue of bad faith in this case required a full trial, as the parties contested the facts surrounding the compromise agreement.
3. Client's Right to Compromise: A client has the right to settle a case without the lawyer's intervention, but the settlement should not deprive the lawyer of his fees. If bad faith is proven, both the client and the adverse party may be held liable for the attorney's fees.
4. Attorney's Fees as Personal Obligation: The payment of attorney's fees is primarily the client's obligation. The adverse party (NPC) would only be liable if it acted in bad faith, which was not established in this case.

Conclusion:

The Supreme Court affirmed the CA's decision, ruling that Atty. Gubat's petition lacked merit. The Court emphasized that summary judgment was improper due to factual disputes, and the issue of bad faith required a full trial. The Court also clarified that while a client may settle a case without the lawyer's intervention, the lawyer is still entitled to reasonable compensation for services rendered.