G.R. No. 120592 - Traders Royal Bank Employees Union-Independent vs. National Labor Relations Commission

On February 26, 1987, Traders Royal Bank Employees Union (the Union) and Atty. Emmanuel Noel A. Cruz (private respondent) entered into a retainer agreement, under which the Union paid a monthly retainer fee of ₱3,000 in consideration of specified legal services.
On April 4, 1990, the Union terminated the retainer agreement.

On March 24, 1987, the Union’s members’ claims for holiday, mid-year, and year-end bonus differentials were filed by private respondent and certified to the NLRC as Case No. 0466.
On September 2, 1988, the NLRC rendered a decision awarding all three differentials in favor of the employees.
Private respondent moved for issuance of a writ of execution; the case was raffled to Labor Arbiter Oswald Lorenzo.
Pending execution, TRB appealed to the Supreme Court.

On August 30, 1990, the Supreme Court modified the NLRC decision by deleting awards for mid-year and year-end differentials but affirming the holiday pay differential.
TRB computed the holiday differential at ₱175,794.32, paid the employees accordingly, and the Union did not contest the computation.

On September 18, 1990, private respondent received the Supreme Court decision.
On October 8, 1990, he notified the Union, TRB, and the NLRC of his right to enforce an attorney’s charging lien over the award.
On July 2, 1991, he filed a motion before Labor Arbiter Lorenzo for determination of his attorney’s fees—10% of ₱175,794.32 (₱17,579.43).
On November 26, 1991, the Labor Arbiter ordered the Union to pay ₱17,574.43 as attorney’s fees.
The Union appealed to the NLRC (December 27, 1991); on October 19, 1994, the NLRC First Division affirmed; reconsideration was denied on May 23, 1995.
The Union then filed the present petition before the Supreme Court, alleging grave abuse of discretion, lack of jurisdiction to award fees after a final judgment, and violation of the retainer agreement.

Did the NLRC lack jurisdiction to award attorney’s fees after the Supreme Court’s final judgment did not award such fees?
Should the Union’s attorney’s fees claim have been filed and resolved in the main case before Supreme Court review?

Did the ₱3,000 monthly retainer cover the services rendered by private respondent in the bonus differential case?
Is private respondent entitled to additional attorney’s fees absent an express agreement under the retainer contract?
What is the proper measure and legal basis for attorney’s fees—Article 111 of the Labor Code, quasi-contract/unjust enrichment, or quantum meruit?