Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 67
Makati City

MAHAR LIKA,
Plaintiff,

- versus Civil Case No. 456987

RANDY LEPAOPAO,
Defendant.
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MOTION TO WITHDRAW
COMES NOW, the undersigned counsel, unto the Honorable Court, most
respectfully states:
1.That the undersigned counsel has already terminated his attorney-client
relationship with the Defendant Randy Lepaopao, particularly because of the
latter's deliberate failure to pay the fees for the undersigned's legal services
despite repeated requests for payment and repeated promises to pay, in
violation of the Defendant's Retainer Contract with the undersigned counsel;
2.That the statement of accounts of the undersigned counsel merely fell on
deaf ears and not a single centavo was paid to this date by the said
Defendant contrary to all its representations;
3.That the undersigned counsel's previous request for said Defendant to give
consent and conformity to the undersigned counsel's Motion for Withdrawal
was never acted upon to this date;
4.That in view of the foregoing reasons, the undersigned counsel could no
longer adequately fulfill his obligations as legal counsel for the said
Defendant;
5.That Rule 22.01 par. (f) of the Code of Professional Responsibility states
that a lawyer may withdraw his services when the client deliberately fails to
pay the fees for the services or fails to comply with the retainer agreement;

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6.That there is a need to protect the members of the legal profession from
clients who take advantages of their professional services. In fact, the
Honorable Supreme Court had the occasion to state that:
"Counsel, any counsel, if worthy of his hire, is entitled to be fully
recompensed for his services. With his capital consisting solely of his brains
and with his skill, acquired at tremendous cost not only in money but in the
expenditure of time and energy, he is entitled to the protection of any judicial
tribunal against any attempt on the part of the client to escape payment of
his fees. It is indeed ironic if after putting forth the best that is in him to secure
justice for the party he represents, he himself would not get his due. Such an
eventuality this Court is determined to avoid. It views with disapproval any
and every effort of those benefited by counsel's services to deprive him of
his hard-earned honorarium. Such an attitude deserves
condemnation."(Albano vs. Coloma, 21 SCRA 411).
7.As such, undersigned most respectfully requests that he be allowed by this
Honorable Court to withdraw his appearance in this case as Counsel for the
Defendant Lepaopao without the latter's express conformity.
PRAYER
WHEREFORE, premises considered, undersigned counsel most
respectfully prays that he be allowed to withdraw his appearance in this case
as counsel for the Defendant Lepaopao, dispensing with the latter's express
conformity, and that he be relieved of all his responsibilities relative to this
case.
Other reliefs just and equitable under the premises are likewise prayed for.
Makati City, Philippines, February 14, 2022

ATTY. JUBI LEE

Counsel

COPY FURNISHED:
ATTY. LERON SINTA
Opposing Counsel

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