Title
Suplico vs. Lokin, Jr.
Case
A.C. No. 9152
Decision Date
Jul 1, 2020
Former law partners filed a disbarment complaint over unpaid attorney's fees, but the Supreme Court dismissed it due to lack of evidence and valid quitclaims.

Case Digest (G.R. No. 135857)

Facts:

  • Parties and Background
    • Petitioners: Atty. Rolex T. Suplico and Atty. Demaree J.B. Raval, former partners in the law firm Raval Suplico and Lokin, Lawyers.
    • Respondents: Atty. Luis K. Lokin, Jr. and Atty. Salvador C. Hizon, who, as former partners, were alleged to have deviated from the agreed distribution of attorney’s fees.
    • The dispute arose from a complaint for disbarment and a concurrent criminal case for estafa, both initiated by the petitioners.
  • Disbarment Complaint and Alleged Fee Arrangement
    • The petitioners filed a complaint before the Integrated Bar of the Philippines (IBP) Commission on Bar Discipline alleging violation of Rule 7.03 and Canon 7 of the Code of Professional Responsibility.
    • The core allegation centered on the respondents’ refusal to turnover their respective shares (purportedly P144,831,371.49, representing 40% of a total recovery of P362,078,428.74) derived from the Aerocom Investors & Managers, Inc. recovery.
    • Allegedly, as partners in the law firm, it was agreed that 30% of the partnership profits would go to Atty. Hizon while the remaining 70% was to be equally divided among petitioners and Atty. Lokin.
  • Evidence and Investigative Proceedings
    • The Investigating Commissioner, Jose I. De la Rama, Jr., issued a report recommending dismissal of the disbarment case, primarily due to the absence of a valid, documented retainer’s agreement for the payment of the 40% fee.
    • Key issues included:
      • The alleged lack of a written agreement despite references by Aerocom’s corporate officers.
      • Inconsistencies in the affidavit of Atty. Jessica A. Los Banos, who failed to identify the document evidencing the supposed fee arrangement.
    • The report noted that the petitioners could not produce a copy of the agreement, while both the President and Corporate Secretary of Aerocom denied its existence.
  • Resolution by the IBP Board of Governors
    • The IBP Board of Governors first adopted the Investigating Commissioner’s recommendation through Resolution No. XVIII-2009-52 and later affirmed it via Resolution No. XIX-2011-484.
    • These resolutions validated that petitioners had received their share from the Aerocom case and had further waived additional claims through executed quitclaims.
  • Quitclaims and Withdrawal of Rights
    • Atty. Suplico executed a quitclaim effective from January 15, 1995, thereby relinquishing any further claim over the distribution of fees from the Aerocom case.
    • Similarly, Atty. Raval’s withdrawal from the partnership (accompanied by a waiver of his rights in exchange for the Amberland office space) effectively barred any further disputes regarding the fee arrangement.

Issues:

  • Existence and Validity of the Fee Agreement
    • Whether the petitioners successfully demonstrated the existence of a valid and binding retainer’s agreement obligating the defunct law firm to pay 40% of the Aerocom recovery as attorney’s fees.
    • Whether the alleged agreement, acknowledged by some parties but denied by Aerocom’s corporate officers, had sufficient evidentiary support.
  • Alleged Violation of Professional Ethics and Misconduct
    • Whether the respondents committed misconduct or acted in bad faith by allegedly failing to remit the petitioners’ share of the agreed-upon fees.
    • Whether such actions, if proven, would constitute a violation of Rule 7.03 and Canon 7 of the Code of Professional Responsibility.
  • Legal Effect of the Executed Quitclaims
    • Whether the executed releases, waivers, and quitclaims by the petitioners effectively nullified any claim over the fee distribution from the Aerocom case.
    • Whether the quitclaims, executed voluntarily and with full knowledge of their implications, dispense with the petitioners’ rights to further financial recovery.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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