Joey R. Peña v. Jesus Delos · G.R. 202223

Petitioner: Joey R. Peña
Respondent: Jesus Delos Santos
Citation: G.R. No. 202223
Court: Supreme Court
Division: Third Division
Ponente: Reyes, J.
Decided: March 2, 2016

Summary

Joey Peña sought substitution in execution proceedings claiming he acquired property rights from the original judgment awardees Jesus Delos Santos and Rosita Delos Santos Flores through their lawyer Atty. Romeo Robiso. The Supreme Court denied Peña's claim, ruling that the conveyance from the clients to their lawyer was void under Article 1491(5) of the Civil Code, which prohibits lawyers from acquiring property that is the object of litigation they are handling. Since the deeds were executed while the case was still pending appeal before the Supreme Court, they were deemed inexistent from the beginning. The Court emphasized that public policy disallows such transactions due to the fiduciary relationship and potential for lawyers to take advantage of clients. Even contingency fee agreements cannot validate transfers made during litigation pendency. Consequently, Peña had no legal standing for substitution.

Statutes applied

Civil Code, Art. 1491

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By the Intellegal Editorial Board · March 2, 2016

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