Title
Manila Building and Loan Association vs. B. A. Green
Case
G.R. No. 31884
Decision Date
Feb 27, 1930
Foreclosure of properties in Manila and Rizal led to disputes over attorney’s fees; court allowed reduced fees, preventing double recovery.

Case Summary (G.R. No. 31884)

Judgments and Initial Considerations

The total judgment awarded in the Court of First Instance of Rizal was P102,597.38, while the judgment in Manila amounted to P103,297.38. The discrepancy between these amounts can be attributed to accumulated interest accrued between the dates of the judgments. Central to the case is the stipulation in the mortgage contracts for attorney's fees, which were set at 10% of the amounts due.

Attorney's Fees Dispute

Defendant B.A. Green admitted the execution of both the note and the mortgage but contested the recoverability of attorney's fees, arguing that the Manila Building & Loan Association is entitled to only one set of attorney's fees despite the parallel proceedings in different jurisdictions. The core of the legal discussion revolved around the interpretation of whether multiple awards of attorney's fees could be justified given the requirements for foreclosure in separate courts for properties in different locations.

Court's Reasoning on Attorney's Fees

The court recognized that the mortgage encompassed real property located in two distinct locations, necessitating actions in both the Manila and Rizal courts for the legal foreclosure process. This dual requirement mandated additional legal effort, justifying the allowance for attorney's fees in both cases. Ultimately, the court decided to award attorney's fees of P7,000 to the Manila Building & Loan Association applicable to the aggregate work across both jurisdictions.

Fees in O’Brien Case

In the case involving O’Brien et al., the mortgage expressly stipulated an attorney's fee of P2,500 for foreclosure actions. The court maintained that the parties bound themselves to this stipulation and thus granted attorney's fees for that specific amount, which would cover all actions related to the mortgage across the courts.

Finality of Judgments

The court mandated that both the Manila Building & Loan Association and O’Brien et al. are entitled to only one satisfaction of their respective judgments. This means that payment

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