PAFLU vs. Binalbagan Isabela Sugar Case Digest
PAFLU vs. Binalbagan Isabela Sugar Case Digest
PAFLU vs. Binalbagan Isabela Sugar Case Digest
COMPLAINANTS PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU), ENRIQUE ENTILA &
VICTORIANO TENAZAS
FACTS OF THE CASE The case is about the petition of Attys. Cipriano Cid &
Associates, who sought to annul the decision of the Court of
Industrial Relations on the attorney’s fee for the legal services
rendered by Quintin Muning, a non-lawyer, that amounted to 10%
compared to the compensation of Atty. Atenacio Pacis which is
only 5%.
- The issue of this case is in connection with the case of “PAFLU et al. vs. Binalbagan
Isabela Sugar Co., et al. before the Court of Industrial Relations, which rendered its
decision in favor of the complainants.
- After the case ended, Cipriano Cid & Associates and Atty. Atanacio Pacis filed their
respective charges for attorney’s fees.
- On the other hand, one Quintin Muning also filed a "Petition for the Award of
Services Rendered" which was opposed by Attys. Cipriano Cid & Associates on the
ground that he is not a lawyer.
- The records showed that the appearances made in behalf of the complainants were
at first by Attorney Pacis and subsequently by respondent Quintin Muning.
- The Court of Industrial Relations rendered its decision for compensation for
professional services. Wherein Atty. Attys. Cipriano Cid & Associates (10%); Atty.
Atanacio Pacis (5%); and a non-lawyer, Quintin Muning (10%)
- The award of 10% to Muning, a non-lawyer, is the reason for this petition.
ISSUE Whether or not a non-lawyer may recover attorney’s fees for legal services
rendered
RULING AND RATIO No. The existence of an attorney-client relationship is a condition for the recovery of
DECIDENDI attorney's fees. Such a relationship cannot exist unless the client's representative in court is
a lawyer.
Since respondent Muning is not one, he cannot establish an attorney-client relationship with
Enrique Entila and Victorino Tenezas or with PAFLU, and he cannot, therefore, recover
attorney's fees. Certainly, public policy demands that legal work in the representation of
parties litigant should be entrusted only to those possessing tested qualifications and who
are sworn, to observe the rules and the ethics of the profession, as well as being subject to
judicial disciplinary control for the protection of courts, clients and the public.
DOCTRINE The principle enunciated in Amalgamated Laborers' Association, et al. vs. Court of
Industrial Relations, et al.
that an agreement providing for the division of attorney's fees, whereby a non-
lawyer union president is allowed to share in said fees with lawyers, is condemned
by Canon 34 of Legal Ethics and is immoral and cannot be justified. An award by a
court of attorney's fees is no less immoral in the absence of a contract, as in the
present case.
Public policy demands that legal work in the representation of parties litigant should
be entrusted only to those possessing tested qualifications and who are sworn, to
observe the rules and the ethics of the profession, as well as being subject to judicial
disciplinary control for the protection of courts, clients and the public.
The reasons are that the ethics of the legal profession should not be violated; 7 that acting as
an attorney with authority constitutes contempt of court, which is punishable by fine or
imprisonment or both,8 and the law will not assist a person to reap the fruits or benefit of an
act or an act done in violation of law;9 and that if were to be allowed to non-lawyers, it
would leave the public in hopeless confusion as to whom to consult in case of
necessity and also leave the bar in a chaotic condition, aside from the fact that non-
lawyers are not amenable to disciplinary measures.