G.R. No. 247724 September 23, 2020
Dimayuga Law Offices, Petitioner, vs. Titan-Ikeda Construction and Development Corporation, Respondent.

FACTS

Primetown Property Group, Inc. engaged Titan-Ikeda Construction for the architectural works of a condominium, with payment to be made via a “full swapping” of condominium units. Primetown later took over the project, alleging Titan-Ikeda had only accomplished 48.71% of the work, resulting in an overpayment. Primetown sued for the return of units. The Supreme Court, in a 2008 Decision, ordered Titan-Ikeda to return the units corresponding to the overpayment, subject to a determination of actual accomplishment and liability, and remanded the case to the RTC for reception of evidence and computation.
During the protracted litigation, Titan-Ikeda engaged the legal services of Atty. Dimayuga. To secure payment of its attorney’s fees, Dimayuga Law Offices caused the annotation of an attorney’s lien and an adverse claim on the titles of the condominium units subject to the litigation. After the Supreme Court’s 2008 remand, the RTC, in an Order dated June 4, 2018, directed the cancellation of these annotations, reasoning that the lien was premature since the exact liability of Titan-Ikeda to Primetown was still undetermined. The Court of Appeals affirmed this order.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in ordering the cancellation of the attorney’s lien and adverse claim annotated on the condominium certificates of title.

RULING

Yes. The Supreme Court granted the petition and set aside the RTC’s order. The Court held that an attorney’s lien is a right in rem that attaches to the judgment or fund awarded to the client as a result of the attorney’s professional services. The lien exists from the moment the attorney renders service and is not contingent upon the finality of a judgment quantifying the client’s monetary award or liability. In this case, the attorney’s services were rendered to protect Titan-Ikeda’s interest in the specific condominium units, which were the very subject matter of the litigation. The fact that the case was remanded for a recomputation of the parties’ liabilities did not negate the existence of the lien or justify its cancellation. The lien rightfully attached to the property in litigation to secure compensation for legal services already performed. The RTC’s order to cancel the lien was a premature deprivation of a substantive right, constituting grave abuse of discretion. The Court emphasized its duty to protect an attorney’s right to just compensation for services rendered.