COLUMNS 1

NUMBER 4

CANON 20

GUENTER BACH v. ONGKIKO KALAW MANHIT

petitioner Guenter Bach engaged the services of respondent law firm Ongkiko Kalaw Manhit & Accorda
Law Offices to represent him for the annulment of the marriage

However, on 5 December 1995, respondent withdrew its appearance as counsel of petitioner, due to
policy differences.

Despite respondent's demands for his legal fees, petitioner failed and refused to pay. Thus, respondent
filed a Complaint

The RTC awarded the respondent The amount of P750,000.00 as plaintiff's lawful fees for services
rendered , plus interest at the rate of 2% per month from the date of demand until paid;

ISSUE

WHETHER OR NOT UNDER THE CONCEPT OF QUANTUM MERUIT, THE AMOUNT OF P750,000.00 AS FEES
FOR SERVICES RENDERED WITH INTEREST PEGGED AT 2% A MONTH FROM DATE OF DEMAND UNTIL
FULLY PAID IS REASONABLE

RULING

YES, We have identified the circumstances to be considered in determining the reasonableness of a claim
for attorney's fees as follows:

Rule 20.1, Canon 20 of the Code of Professional Responsibility enumerates the following factors which
should guide a lawyer in determining his fees:

(a) the time spent and extent of services rendered or required;

(b) the novelty and difficulty of the questions involved;

(c) the importance of the subject matter;

(d) the skill demanded;

(e) the probability of losing other employment as a result of the acceptance of the proffered case;
(f) the customary charges for similar services and the schedule of fees of the IBP Chapter to which he
belongs;

(g) the amount involved in the controversy and the benefits resulting to the client from the service;

(h) the contingency or certainty of compensation;

(i) the character of the employment, whether occasional or established; and

(j) the professional standing of the lawyer.