G.R. No. 211522 - J' Marketing Corp. vs. Iguiz

In August 1990, Spouses Pedro and Rosita de Guzman engaged Atty. Francisco L. Rosario, Jr. as their defense counsel in a complaint filed by Loreta A. Chong involving annulment of contract and recovery of possession with damages concerning a parcel of land in Parañaque City covered by TCT No. 1292 (266 sq. meters).
Their legal battle started at the RTC and culminated at the Supreme Court, with Spouses de Guzman, represented by petitioner, prevailing at all levels.

While the appeal was pending in the Supreme Court, Spouses de Guzman died in a vehicular accident.
They were substituted by their children: Rosella de Guzman-Bautista, Lellani de Guzman, Arleen de Guzman, and Philip Ryan de Guzman (respondents).

On September 8, 2009, petitioner filed a Motion to Determine Attorney's Fees before the RTC, claiming an oral agreement with the deceased spouses for 25% of the market value of the subject land if the complaint would be dismissed.
Petitioner demanded payment based on quantum meruit since respondents refused to pay the contracted attorney's fees despite successful representation.
The RTC denied the motion on November 23, 2009, ruling the motion was filed out of time because the judgment had become final and executory on October 31, 2007, and the court lost jurisdiction.
Petitioner’s motion for reconsideration was also denied.

Respondents argued that the motion was belated, and that the RTC already awarded P10,000.00 as attorney's fees during the case.
They asserted Article 2208 of the Civil Code requires written agreements for attorney’s fees, which was lacking here.
Respondents also denied knowledge of any oral contract and claimed 25% of the land’s market value was excessive.

Whether the RTC committed reversible error in denying the Motion to Determine Attorney’s Fees on the ground that it had lost jurisdiction after the judgment had become final and executory.
Whether the RTC erred in ruling that awarding attorney’s fees would cause a variance or amendment of the final and executory judgment.
Whether the finality of the decision barred petitioner from filing the motion to recover attorney’s fees.