Case Summary (G.R. No. 222538)
Antecedents of the Case
In 2002, Riguer retained Atty. Mateo to provide legal services concerning the aforementioned land. Their agreement included several compensation elements: an acceptance fee, an appearance fee, and pleading fees, all of which Riguer paid. Following a favorable judgment from the Regional Trial Court (RTC) on January 16, 2007, Atty. Mateo had Riguer sign a document termed "Kasunduan," which stipulated additional fees contingent on the outcome of the case and the eventual sale of the land. After Atty. Mateo demanded payment post-appeal victory, Riguer refused, leading to Atty. Mateo filing a Complaint for Collection of Attorney’s Fees.
Rulings of the Lower Courts
The Municipal Trial Court in Cities (MTCC) ruled on July 26, 2013, in favor of Atty. Mateo, enforcing the terms of the Kasunduan despite Riguer's claims of lack of awareness regarding the document. Riguer's defense was dismissed as speculative, noting he did not deny signing the document. The MTCC awarded Atty. Mateo P250,000.00 in fees plus interest and costs.
Riguer appealed to the RTC, which upheld the MTCC ruling, confirming the binding nature of the Kasunduan and the reasonableness of the attorney's fees as per quantum meruit principles. Riguer's subsequent appeal to the Court of Appeals (CA) was also denied, affirming the lower court's findings and rejecting claims of procedural errors related to the service of decisions and alleged misrepresentation in signing the Kasunduan.
Issues Presented
Two primary issues were presented: (1) Whether Riguer's motion for reconsideration of the CA's April 13, 2015 decision was filed timely; and (2) Whether Atty. Mateo was entitled to the P250,000.00 in attorney's fees specified in the Kasunduan.
Timeliness of Motion for Reconsideration
The Court confirmed that the CA correctly determined the 15-day period to file a motion for reconsideration commenced on May 15, 2015, when the decision was received by Macaldo, not from subsequent notifications to Riguer’s former counsel. The CA's ruling that the reconsideration motion was untimely was thus sustained.
Allegations of Fraud and Misrepresentation
Riguer's assertion of being misled into signing the Kasunduan was deemed unsupported by clear and convincing evidence. The burden was on Riguer to prove his claims of fraud, which he failed to substantiate, thereby binding him to the stipulations of the Kasunduan.
Evaluation of Attorney's Fees
While the Court acknowledged the validity of Atty. Mateo's claim for att
...continue readingCase Syllabus (G.R. No. 222538)
Case Overview
- This case involves a petition for review on certiorari filed by Eduardo N. Riguer (petitioner) against Atty. Edralin S. Mateo (respondent) concerning the collection of attorney's fees.
- The petition seeks to reverse the decisions and resolutions of the Court of Appeals (CA) which upheld previous rulings from the Regional Trial Court (RTC) and Municipal Trial Court in Cities (MTCC).
Procedural History
- The case began when Riguer engaged Atty. Mateo's services in 2002 for representation in civil and criminal cases concerning a parcel of land.
- They entered into an agreement where Riguer would pay Atty. Mateo an acceptance fee, appearance fee, and pleading fees, all of which Riguer paid consistently.
- Following a favorable judgment for Riguer in a civil case in January 2007, Atty. Mateo had Riguer sign a document titled "Kasunduan," which outlined additional fees to be paid upon certain conditions.
- After Atty. Mateo demanded payment following the successful appeal, Riguer refused, leading to Atty. Mateo's filing of a complaint for collection of attorney's fees in May 2011.
MTCC Ruling
- The MTCC ruled in favor of Atty. Mateo, ordering Riguer to pay P250,000.00 in attorney's fees plus legal interest and costs of suit.
- The decision held that Riguer was bound by the &qu