Title
Francisco Motors Corp. vs. Court of Appeals
Case
G.R. No. 117622-23
Decision Date
Oct 23, 2006
A 1958 case involving attorney’s fees from property litigation, contested land transfers, and enforcement delays, culminating in a Supreme Court ruling on certiorari, judgment execution, and good faith purchase rights.

Case Summary (G.R. No. 117622-23)

Case Overview

This case involves a petition for review by FMC challenging a decision of the Court of Appeals that granted Raquiza's right to execute a judgment concerning attorney's fees related to properties owned by the Alano spouses. The dispute centers around attorney’s fees Raquiza claimed for his representation of the Alano spouses in certain civil cases.

Background Facts

The case traces back to 1958 when the Alano spouses hired Raquiza as legal counsel. They agreed to pay attorney's fees amounting to 30% of the properties involved in their litigation. After being dismissed without cause, Raquiza intervened in Civil Cases Nos. 2608 and 4622 to secure his claims. By 1970, the court ruled that Raquiza was entitled to fees from the properties, which included a notable reversion of certain titles over time, leading to FMC acquiring properties previously owned by the Alanos.

Legal Proceedings

Raquiza sought enforcement of the appellate court's judgment, which had become final in 1981, retaining his right to collect 30% of the properties. FMC contested this enforcement at multiple legal levels, asserting good faith in the purchase of the property without notice of any encumbrances. The lower courts issued several orders regarding the enforcement of the judgment, leading to various motions and appeals, culminating in FMC's argument that it should not be held liable for Raquiza's fees.

Issues Presented

The issues analyzed by the Court revolve around three key points:

  1. Whether the proper remedy for Raquiza was through certiorari rather than appeal.
  2. Whether the decision of the Court of Appeals in a previous case could be enforced by a motion after several years.
  3. Whether the attorney's fees awarded to Raquiza could be satisfied against the parcels of land acquired by FMC.

Court's Analysis and Rulings

The Supreme Court held that Raquiza's resort to certiorari was appropriate given the lengthy delay in resolving his claims and the absence of effective remedies through appeal due to the protracted nature of the litigation. The Court noted that the attorney's lien was not annotated on the titles at the time FMC purchased the property, thereby qualifying FMC as a good faith pu

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