- Petitioner
- Philippine National Construction Corporation
- Respondent
- Apac Marketing Corporation
- Citation
- G.R. No. 190957
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Sereno, C.J.
- Decided
- June 5, 2013
Summary
This Supreme Court case involves a commercial dispute between PNCC and APAC Marketing over payment for crushed basalt rock materials. While PNCC eventually paid the principal obligation, the lower courts awarded attorney's fees to APAC. The Supreme Court reversed, holding that attorney's fees under Article 2208 of the Civil Code require specific factual, legal, and equitable justification. The Court emphasized that attorney's fees are exceptional, not routine awards, and courts must clearly articulate the legal basis. The RTC's finding that APAC was 'compelled to litigate' was insufficient under Article 2208's enumerated exceptions. This decision reinforces the restrictive approach to attorney's fees awards and the requirement for detailed judicial reasoning in granting such awards.