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Quilban V. Robinol Facts:: (A.M. No. 2144, April 10, 1989) (171 SCRA 768)

Atty. Robinol represented squatters in a land dispute case against a realtor. He was able to get the decision reversed on appeal. The squatters then raised P75,000 to pay the realtor per the court order, but Atty. Robinol did not make the payment and claimed he had a lien over the funds for his legal services. The court found Atty. Robinol guilty of ethical violations for retaining his clients' funds intended for a specific purpose without justification. As there was an express contract regarding compensation, the principle of quantum meruit did not apply to allow him to keep the funds.

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Martin Tongco Fontanilla
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101 views1 page

Quilban V. Robinol Facts:: (A.M. No. 2144, April 10, 1989) (171 SCRA 768)

Atty. Robinol represented squatters in a land dispute case against a realtor. He was able to get the decision reversed on appeal. The squatters then raised P75,000 to pay the realtor per the court order, but Atty. Robinol did not make the payment and claimed he had a lien over the funds for his legal services. The court found Atty. Robinol guilty of ethical violations for retaining his clients' funds intended for a specific purpose without justification. As there was an express contract regarding compensation, the principle of quantum meruit did not apply to allow him to keep the funds.

Uploaded by

Martin Tongco Fontanilla
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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QUILBAN V.

ROBINOL
(A.M. No. 2144, April 10, 1989)
(171 SCRA 768)
FACTS:
Congressman Luis R. Taruc broached the idea of donating or selling a parcel of land somewhere
in Quezon City to the squatters. Following such advice, the squatters formed the Samahang
Pagkakaisa ng Barrio Bathala, with Bernabe Martin as President. However, Martin sold the said
land to Maximo Rivera, a realtor, to the exclusion of the other Samahan members. The members
of the Samahan filed a civil case against Rivera but were dismissed. On appeal, they hired Atty.
Santiago R. Robinol. The latter was able to obtain a reversal of the said decision. The Court of
Appeals ordered that Rivera be reimbursed the amount of P41,961.65 for the expenses he
incurred for the land. The officers of the Samahan raised a total amount of P75,000.00 and gave it
Atty. Robinol. However, he made no payment to Rivera. As a consequence, complainants filed an
administrative case against him for unethical practice. On the other hand, Atty. Robinol claims
lien over the subject money in lieu of the services rendered by him invoking the principle of
quantum meruit.

ISSUES: Whether or not respondent can be held guilty of ethical infractions and grave
misconduct.

HELD:
YES. His violation was that he retained in his possession his clients funds intended for
a specific purpose. His act, under the circumstances, was highly unjust for him to have done so.
His clients were mere squatters who could barely eke out an existence. Atty. Robinol he is bereft
of any legal right to retain his clients' funds intended for a specific purpose the purchase
of land. He stands obliged to return the money immediately to their rightful owners. The
principle of quantum meruit applies if a lawyer is employed without a price agreed upon for his
services in which case he would be entitled to receive what he merits for his services, as much
as he has earned. In this case, however, there was an express contract and a stipulated mode of
compensation. The implied assumption quantum meruit therefore, is inapplicable.

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