G.R. No. 222538 - Riguer vs. Mateo

In 2002, petitioner Eduardo N. Riguer engaged respondent Atty. Edralin S. Mateo to represent him in civil and criminal cases involving a parcel of land covered by Transfer Certificate of Title (TCT) No. 12112.
The parties agreed that Atty. Mateo’s compensation would be composed of an acceptance fee, appearance fee, and pleading fees, which Riguer paid regularly.

During the pendency of the civil case appeal, after a favorable RTC judgment on January 16, 2007, Atty. Mateo obtained Riguer’s signature on a document titled “Kasunduan.”
The Kasunduan stipulated the following payment obligations from Riguer:

The Municipal Trial Court in Cities (MTCC) issued a July 26, 2013 decision ruling in favor of Atty. Mateo, ordering Riguer to pay ₱250,000.00 with six percent interest plus costs.
Riguer appealed the MTCC decision:

The Regional Trial Court (RTC) affirmed the MTCC ruling on June 2, 2014, deeming the Kasunduan binding and upholding the award on the basis of quantum meruit.
The Court of Appeals (CA) sustained the RTC decision in its April 13, 2015 ruling, rejecting Riguer’s defense that the Kasunduan was merely lumped with other documents and that no valid appeal had yet been made when it was signed.

His first motion was asserted to be timely despite the CA ruling that the 15‑day period (reckoned from May 15, 2015—the date a copy was received by Macaldo) had been violated, since the motion was actually filed on June 2, 2015.
A second motion for reconsideration was filed but was summarily denied as it was barred by Section 2, Rule 52 of the Rules of Court.

The decision was allegedly served at his counsel’s family home rather than at the official office address.
A certain Marisol Macaldo, not affiliated with Riguer’s counsel, received the notice.

He was misled into signing the Kasunduan since it was part of a voluminous set of documents for the appeal, and he lacked the sophistication due to his limited education and advanced age.
The stipulated fee of ₱250,000.00 was exorbitant, especially in light of the fact that the land eventually sold for only ₱600,000.00.
The figures regarding expense and success fees (₱30,000.00 and ₱50,000.00) were paid based on verbal instructions separate from the written agreement.

The CA properly ruled on the timeliness of Riguer’s motion based on the certified service via registered mail.
The Kasunduan was valid and binding, and even if nullification were considered, attorney’s fees were recoverable on a quantum meruit basis.
The stipulated ₱250,000.00 fee was justified considering that the purported value of the litigated property was around ₱3 million, despite the deed of sale reflecting a lower price.

Whether Riguer’s motion for reconsideration of the April 13, 2015 CA decision was timely filed, particularly in view of the proper method and timing of service via registered mail.
Whether Atty. Mateo is entitled to recover the stipulated attorney’s fees (originally ₱250,000.00) based on the Kasunduan, or whether, due to issues of alleged fraud and unconscionability, the fees should be reduced.