Petitioner
Francisco L. Rosario, Jr.
Respondent
Lellani de Guzman
Citation
G.R. No. 191247
Court
Supreme Court
Division
Third Division
Ponente
Mendoza, J.
Decided
July 10, 2013

Summary

This case involves lawyer Atty. Francisco L. Rosario, Jr.'s claim for attorney's fees based on an alleged oral agreement with deceased clients Spouses Pedro and Rosita de Guzman for 25% of property value in exchange for legal services. After successfully defending them in a civil case for 17 years (1990-2007), petitioner filed a Motion to Determine Attorney's Fees in 2009, which the RTC denied as untimely. The Supreme Court reversed, distinguishing between ordinary attorney's fees (professional compensation) and extraordinary attorney's fees (damages), ruling that the motion was timely under the 6-year prescriptive period for oral contracts. Applying quantum meruit principles and considering factors under Rule 20.01 of the Code of Professional Responsibility, the Court awarded 15% of the property's market value as reasonable attorney's fees, emphasizing lawyers' right to just compensation for professional services rendered.

Statutes applied

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By the Intellegal Editorial Board · July 10, 2013

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