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	GR No. 176530 2009-06-16	SPS. CONSTANTE AGBULOS AND ZENAIDA PADILLA AGBULOS v. NICASIO GUTIERREZ CHICO-NAZARIO, J.
In any case, an unauthorized appearance of an attorney may be ratified by the client either expressly or impliedly. Ratification retroacts to the date of the lawyer's first appearance and validates the action taken by him.[10] Implied ratification may take various forms, such as by silence or acquiescence, or by acceptance and retention of benefits flowing therefrom.[11] Respondents' silence or lack of remonstration when the case was finally elevated to the CA means that they have acquiesced to the filing of the appeal.
	GR NO. 154019 2006-08-10	JULIAN ELBIÑA v. CENIZA CORONA, J.
In accordance with our ruling in Landbank v. Pamintuan Development Corporation,[18] there is no question that a party may have two or more lawyers working in collaboration in a given litigation. However, a substitution should not be presumed from the mere filing of a notice of appearance of a new lawyer. The fact that a second attorney enters his appearance for the same party does not necessarily raise the presumption that the authority of the first attorney has been withdrawn.[19]