Title
Lizardo, Sr. vs. Montano
Case
G.R. No. 138882
Decision Date
May 12, 2000
A trial court's order for attorney's fees over a decade after judgment satisfaction was voided due to loss of jurisdiction.
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Case Digest (G.R. No. 138882)

Facts:

  • Jose S. Lizardo, Sr. is the petitioner; Atty. Carmelito A. Montano is the respondent.
  • On April 8, 1983, the Regional Trial Court of Kalookan City, Branch 125, decided Civil Case No. C-9009, a collection suit by Lizardo against Eddie H. Mirano.
  • The court ordered Mirano to pay Lizardo P19,893.95, with 12% interest per annum from August 25, 1980, and 25% of the amount as attorney's fees, plus costs.
  • The decision became final and executory as no appeal was filed.
  • On October 24, 1985, a writ of execution was issued; a parcel of land owned by Mirano was sold at public auction to Lizardo for P44,239.47.
  • The trial court consolidated the title to the property in Lizardo's name on March 14, 1986, and a new title was issued on September 9, 1986.
  • On January 5, 1996, Atty. Montano filed a motion for attorney's fees despite the case being fully satisfied over thirteen years prior.
  • The trial court ordered Lizardo to pay Montano 25% of the property value as attorney's fees on January 29, 1996, without a hearing.
  • Lizardo contested this order and appealed to the Court of Appeals on July 30, 1997.
  • The Court of Appeals dismissed his petition on October 20, 1998, leading Lizardo to file a petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Jose S. Lizardo, Sr.
  • The Court declared the trial court's order dated January 29, 1996, void, as the cou...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the principle that a court loses jurisdiction over a case once its decision becomes final and executory, except for executing the judgment.
  • The trial court's decision in 1983 was final and executory, and the judgment was fully satisfied by 1985.
  • The absence of any action ...continue reading

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