Case Summary (G.R. No. 148606)
Background Facts
While Governor Rene Espina was on official business, a resolution enabling the donation of 210 province-owned lots was enacted by the Vice-Governor, Priscillano Almendras, and three members of the Provincial Board. The donation aimed at facilitating public projects for the City of Cebu was executed and approved without the Governor's knowledge, igniting opposition from concerned taxpayers and government officials who sought legal action to nullify the donation, resulting in a complex legal battle.
Legal Proceedings Initiated
In December 1965, an initial case (Civil Case No. R-8669) was filed to declare the donation illegal. However, the court dismissed this case on procedural grounds. This dismissal prompted Governor Espina to engage Attorney Pablo P. Garcia to pursue further legal remedies to nullify the donation and reclaim the province-owned lots, leading to multiple amendments and appearances by new parties throughout the long legal saga that ensued.
Compromise Agreement and Court Decisions
Over the years, a compromise was reached between the Province of Cebu and the City of Cebu. The Court approved this compromise on July 15, 1974, stipulating the return of certain properties to the Province while authorizing a payment to the City. Following these developments, Attorney Garcia filed a Notice of Attorney's Lien in which he claimed entitlement to compensation for his legal services under quantum meruit based on his significant contributions to the initial legal success for the province.
Opposition to Claim for Attorney’s Fees
The Province of Cebu contested Garcia's claims for attorney's fees, arguing that he was employed without proper authority from the Provincial Board, making any contract of employment ultra vires. However, the surrounding circumstances and failure of the Provincial Board to act were considered, ultimately leading the Court of First Instance of Cebu to rule in Garcia's favor. The matter was appealed to the Intermediate Appellate Court.
Intermediate Appellate Court’s Ruling
On appeal, the Intermediate Appellate Court upheld the trial court's ruling that Garcia was entitled to attorney’s fees but modified the compensation amount to 5% of the market value of the litigated properties. This ruling precipitated further appeals by both parties regarding the legitimacy of the compensation structure.
Supreme Court Review and Conclusion
The Supreme Court ultimately set aside the Intermediate Appellate Court's decision and reinstated the lower court's ruling that awarded Garcia a fee based on quantum meruit at the amount of PHP 30,000. This affirmation underscores the judicial recognition of the essential and beneficial role of Gar
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Case Overview
- This case is a petition for review of a decision made by the Intermediate Appellate Court regarding A.C. G.R. CV No. 66502, which involved former Governor Rene Espina and Mayor Sergio Osmena, Jr., with Atty. Pablo P. Garcia as the claimant for compensation for legal services rendered on behalf of the Province of Cebu.
- The Supreme Court decision was penned by Justice Gutierrez, Jr. and issued on January 29, 1987.
Factual Background
- On February 4, 1964, during Governor Rene Espina's absence, the Vice-Governor Priscillano Almendras and three Provincial Board members enacted Resolution No. 188, donating 210 province-owned lots in Cebu City to the City of Cebu.
- The donation was executed and notarized without opposition, with the aim of financing public improvement projects through the sale of these lots.
- Upon returning, Governor Espina opposed the donation as illegal and immoral, prompting a lawsuit by concerned citizens, including Atty. Garcia, to declare the donation null and void.
Legal Proceedings
- The initial lawsuit (Civil Case No. R-8669) was dismissed due to lack of legal standing of the plaintiffs.
- Despite the dismissal, Garcia later filed a new complaint seeking to annul the deed of donation, which led to the issuance of a preliminary injunction against the City of Cebu from selling the lots.
- A series of legal actions ensued, includi