Case Digest (G.R. No. 91879) Core Legal Reasoning Model
Facts:
This case involves the Heirs of Maximo Regoso (petitioners) seeking a review of the Court of Appeals’ resolution dated October 9, 1989, which dismissed an appeal filed by Maximo Regoso’s former counsel, Attorney Adriano Javier, Sr. The underlying case, Civil Case No. 1464-V-81, was a judicial partition suit with accounting and damages filed by Belen Cruz-Regoso (respondent), the wife of Maximo Regoso, before the Regional Trial Court (RTC), Branch XV of Malolos, Bulacan. The RTC rendered a decision on November 14, 1988, declaring certain properties as either paraphernal or conjugal properties of the parties, ordering the defendant to render accounting, and awarding moral, exemplary damages and attorney’s fees in favor of Belen Cruz-Regoso. Importantly, Maximo Regoso died on January 17, 1985, after submission of the case but before the judgment was promulgated. His death was not reported to the RTC, and thus no substitution by his heirs or legal representatives occurred. Attorney
Case Digest (G.R. No. 91879) Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- The heirs of Maximo Regoso (petitioners) seek review of the Court of Appeals (CA) resolution dismissing the appeal filed by Regoso’s former counsel.
- The case arose from an action for judicial partition of property with accounting and damages (Civil Case No. 1464-V-81) filed by Belen Cruz-Regoso (plaintiff/respondent) against her husband, Maximo Regoso (defendant), in the Regional Trial Court (RTC), Branch XV, Malolos, Bulacan.
- Trial Court Decision
- On November 14, 1988, the RTC rendered judgment declaring:
- The land at Sampalukan, Calvario, Meycauayan, Bulacan as paraphernal property of the plaintiff.
- The building and improvements thereon as conjugal property of both parties.
- Other properties at Galas, Quezon City and Echague, Isabela as conjugal properties.
- Defendant ordered to render accounting of income from these properties.
- Defendant adjudged to pay P5,000.00 moral damages, P5,000.00 exemplary damages, and P5,000.00 attorney’s fees, with costs against him.
- Death of Defendant and Proceeding After
- Maximo Regoso died on January 17, 1985, after submission of the case but before decision promulgation.
- The RTC was not informed of his death before rendering the decision.
- On November 29, 1988, Attorney Adriano Javier, Sr., Regoso’s counsel, filed a notice of appeal which the RTC approved.
- The appeal was docketed in the Court of Appeals as CA-G.R. No. 20183.
- Motion to Dismiss the Appeal and CA Resolution
- Belen Cruz-Regoso, through counsel, moved to dismiss the appeal arguing that:
- Defendant’s legal personality ceased upon death.
- Attorney Javier’s authority to represent Regoso terminated upon the latter’s death.
- Therefore, the notice of appeal filed by Javier was invalid.
- The Court of Appeals dismissed the appeal on October 6, 1989, holding:
- Lawyer-client relationship terminates automatically upon client’s death except in limited exceptions (contract for services to judgment, contingent fees, or appearance coupled with interest).
- None of the exceptions applied here, so the notice of appeal filed after death was a “mere scrap of paper” and without legal effect.
- The petitioners’ motion for reconsideration was denied.
- Petitioners’ Allegation on Appeal
- The heirs contest the CA’s dismissal of the appeal.
- They contend the trial court’s judgment after the defendant’s death is null and void.
Issues:
- Whether the attorney’s authority to represent a client continues after the client’s death for purposes of filing an appeal.
- Whether the trial court’s judgment rendered after the death of defendant, without substitution, is valid and binding on the defendant’s legal representatives or successors-in-interest.
- Whether the failure of counsel to notify the court of defendant’s death affects the validity of the judgment and appeal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)