- Petitioner
- Atty. Martin T. Suelto
- Respondent
- Nelson A. Sison
- Citation
- G.R. No. 158130
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Carpio Morales, J.
- Decided
- July 29, 2005
Summary
Attorney Martin T. Suelto, retained by Santos Land Development Corporation, finalized and notarized a Memorandum of Agreement for land sale between Santos Land and the Sison brothers, and prepared a related Joint Affidavit of Clarification and Confirmation. The MOA provided that notarial and attorney's fees would be charged to a 10% retention of the purchase price. When Suelto billed P604,123.05, the Sisons refused payment, claiming they never hired him and that Santos Land should pay as his client. The Regional Trial Court awarded P100,000 as reasonable fees based on quasi-contract principles under Article 2142 of the Civil Code. The Court of Appeals reversed, but the Supreme Court reinstated the RTC decision, holding that the Sisons were bound by the MOA provision regarding payment of notarial fees from the retention regardless of which lawyer provided the services. The case establishes that parties who benefit from legal services may be liable for reasonable compensation even without a direct attorney-client relationship, based on quasi-contract and unjust enrichment principles.