Title
Rotea vs. Delupio
Case
G.R. No. 45310
Decision Date
Apr 14, 1939
Attorney Rotea, acting as negotiorum gestor, secured minors' property rights, entitling him to compensation and retention rights despite lack of formal authority.

Case Summary (G.R. No. 45310)

Factual Background

In October 1934, Simplicio Birondo, the father of Josefina and Sofia, engaged the services of Attorney Rotea to annul a sale of land executed by Francisca Delupio, the children's grandmother, to Fabian Franco on June 6, 1931. The land in question, identified as lot No. 1023 of the Hacienda Piedad in Baesa, Caloocan, Rizal, was inherited by the minors from their mother. As part of their agreement, Rotea was to receive one third of the land as compensation for his professional services, with expenses related to obtaining the certificate of title to be borne by him.

Actions Taken by Attorney Rotea

Attorney Rotea successfully petitioned the Bureau of Lands, resulting in the nullification of Delupio's sale and the subsequent issuance of Certificate of Title No. 27823 in the minors' names. He also represented the minors in two civil cases pertaining to this matter. On April 25, 1936, the Court of First Instance ordered the notation of Rotea's right of retention over one third of the land, but this order was later contested by Delupio.

Legal Proceedings

On May 9, 1936, Delupio filed for reconsideration of the court's order, arguing that Simplicio Birondo lacked the authority to contract regarding the minors' properties. The court initially sided with Delupio, setting aside the earlier order. However, on July 7, 1936, the court reinstated the notation of Rotea's right of retention, leading to Delupio's appeal.

Legal Issue Presented

The primary legal question addressed by the court was whether Attorney Rotea was entitled to compensation for the services rendered on behalf of the minor daughters in light of the agreement with their father, who was not their legal guardian regarding property matters.

Decision on Attorney Rotea's Rights

The court ruled that even though Simplicio Birondo, as the father, lacked authority to contract for the minors’ properties, Rotea’s actions in defending their interests constituted the role of a "ne

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