GR 164886; (November, 2009) (Digest)
G.R. No. 164886 ; November 24, 2009
JOSE FELICIANO LOY, JR., RAYMUNDO HIPOLITO III, and EDGARDO RIDAO, Petitioners, vs. SAN MIGUEL CORPORATION EMPLOYEES UNION-Philippine Transport and General Workers Organization (SMCEU-PTGWO), as represented by its President Ma. PILAR B. AQUINO and SAN MIGUEL CORPORATION CREDIT COOPERATIVE, INC., as represented by its President Daniel Borbon, Respondents.
FACTS
Petitioners, who are lawyers, filed a complaint to collect attorney’s fees for legal services rendered to respondent San Miguel Corporation Employees Union (SMCEU-PTGWO) in negotiating its 1992-1995 Collective Bargaining Agreement. They claimed entitlement to fees based on a Board Resolution (No. 93-02-28) and sought a writ of preliminary attachment, leading to the garnishment of ₱3 million from union funds. The Union, under its new set of officers, contested the validity of the board resolution and the reasonableness of the claimed fees. After a compromise agreement was invalidated, petitioners filed a Motion for Summary Judgment, arguing the Union’s judicial admissions established its liability.
The Regional Trial Court granted the motion for summary judgment and ordered the release of the garnished funds to petitioners. The Court of Appeals reversed this decision, nullifying the summary judgment. It held that genuine issues of material fact existed, particularly regarding the validity of the board resolution authorizing the fees and the reasonableness of the amount claimed, which necessitated a full trial.
ISSUE
Whether the Court of Appeals correctly ruled that the trial court erred in granting the motion for summary judgment.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed its decision, holding that the case was not ripe for summary judgment. Summary judgment is proper only when, based on the pleadings, affidavits, and admissions, no genuine issue as to any material fact exists and the moving party is entitled to judgment as a matter of law. Here, a genuine issue of material fact was present. The determination of the reasonable amount of attorney’s fees requires the presentation of evidence, as the claimed fees must be evaluated based on factors such as the extent of services rendered, the importance of the subject matter, and the professional standing of the attorneys, pursuant to Rule 138, Section 24 of the Rules of Court.
The Union’s answer, while admitting that legal services were rendered, specifically put in issue the validity of Board Resolution No. 93-02-28 and the reasonableness of the ₱3 million claim. These are factual matters that cannot be resolved solely through pleadings. The existence of these contested facts precludes summary adjudication, as they call for the presentation of evidence in a full-blown trial to ascertain the truth. Therefore, the trial court erred in cutting short the proceedings via summary judgment.