GR 37386; (September, 1933) (Digest)
G.R. No. 37386; September 19, 1933
ANDRES JAYME, plaintiff-appellee, vs. BUALAN, ET AL., defendants-appellants.
FACTS
In 1921, Bagobo Bualan and others engaged Attorney Andres Jayme to recover possession of their land from their former attorneys, Sarenas and Braganza, who had taken control of it. Jayme negotiated an amicable settlement, resulting in the Bagobos regaining the land upon paying P6,000 to Sarenas and Braganza. Jayme received a total of P7,020 from the Bagobos (P1,270 and P5,750). The Bagobos also signed a promissory note in favor of Jayme for P15,000 as attorney’s fees. Jayme filed suit to recover this P15,000. The Bagobos (defendants-appellants) contended that Jayme’s services were only worth the P1,270 already received and that the P5,750 was a loan he should return.
ISSUE
Whether Attorney Andres Jayme is entitled to recover the P15,000 stipulated in the promissory note as compensation for his professional services.
RULING
No. The Supreme Court reversed the trial court’s judgment awarding Jayme P15,000. The Court held that while a written contract for attorney’s fees generally controls, a different standard applies when the client is an “ignorant non-Christian” of whose rights the law takes tender care, and the attorney possesses superior knowledge. Evaluating Jayme’s services on a quantum meruit basis, considering the importance of the subject matter (land valued at approximately P100,000), the extent of services rendered (drafting a complaint, securing an amicable settlement, and drafting a mortgage), and his professional standing, the Court found that the P7,020 already received by Jayme constituted sufficient and reasonable compensation. The Bagobos were not required to pay anything more.
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