G.R. No. 127520 . February 9, 2007.
AURORA FE B. CAMACHO, Petitioner, vs. COURT OF APPEALS and ANGELINO BANZON, Respondents.

FACTS

Petitioner Aurora Camacho owned a parcel of land in Balanga, Bataan. On July 14, 1968, she entered into a written “Contract of Attorney’s Fee” with respondent Atty. Angelino Banzon. The contract stipulated that for Banzon’s legal services in negotiating with the municipal government to have the lot designated as the site for the new public market, selling a portion, and handling incidental legal work, Camacho would compensate him with a 5,000-square-meter portion of the same lot. Banzon performed the services, which included sending a proposal to the council and facilitating a donation of part of the land to the municipality. Camacho later terminated Banzon’s services in 1973.
Atty. Banzon filed a Complaint-in-Intervention in a related forcible entry case to enforce the contract. He sought the delivery of the 5,000-square-meter portion as stipulated, plus additional areas allegedly agreed upon orally for handling other cases. The Regional Trial Court ruled in favor of Banzon, ordering Camacho to deliver the 5,000-square-meter portion. The Court of Appeals affirmed this decision but deleted awards for other claimed areas, finding no sufficient evidence for the oral agreements.

ISSUE

The core issue is whether the written “Contract of Attorney’s Fee” is valid and enforceable, entitling Atty. Banzon to the stipulated compensation of 5,000 square meters of land despite the subsequent termination of his legal services by Camacho.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, upholding the validity and enforceability of the written contract. The legal logic is anchored on contract law and the rules governing attorney-client relations. A contract for attorney’s fees, like any other contract, is binding if it possesses the essential elements of consent, object, and cause. The written agreement dated July 14, 1968, clearly expressed the meeting of minds between Camacho and Banzon: Banzon would perform specific legal services, and in return, Camacho would pay him with a portion of the land.
The Court emphasized that a client may dismiss their attorney at any time. However, under Section 26, Rule 138 of the Rules of Court, if the attorney-client contract is in writing and the dismissal is without justifiable cause, the attorney is entitled to recover the full compensation stipulated. Camacho terminated Banzon’s services after he had substantially performed his contractual duties—the municipal government had already accepted the donation of the land for the market site. Her dismissal was therefore without justifiable cause. Consequently, Banzon earned his full fee upon the successful completion of the core undertaking. The contract was not unconscionable, and Banzon’s right to the stipulated quantum meruit vested upon his performance. The claim for additional compensation based on alleged oral agreements was correctly denied for lack of proof.