Motion to Withdraw Appearance as Counsel for Cause

(CAPTION)
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 _____________, particularly because of the latters deliberate failure to pay the fees
for the undersigneds legal services despite repeated requests for payment and repeated promises
to pay, in violation of the Defendants 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 counsels previous request for said Defendant to give consent and
conformity to the undersigned counsels 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;
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 counsels 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 _____________ without the
latters 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 _____________,
dispensing with the latters 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.
_____________, Philippines, __Date__.
(COUNSEL)
(NOTICE OF HEARING)
(EXPLANATION)
COPY FURNISHED:
OPPOSING COUNSEL