Sibayan v. De Guzman

CourtUnited States Bankruptcy Court, E.D. California
DecidedJune 9, 2025
Docket24-02029
StatusUnknown

This text of Sibayan v. De Guzman (Sibayan v. De Guzman) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sibayan v. De Guzman, (Cal. 2025).

Opinion

1 FOR PUBLICATION 2 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF CALIFORNIA 3 In re: JUNDER JOE BASBAS DE ) 4 GUZMAN and SONIA CAMACHO DE ) GUZMAN ) Case No. 23-24575-C-7 5 ) Debtors. ) 6 ) ELMAR SIBAYAN, ) Adv. Pro. 2024-02029 7 Plaintiff, ) v. ) 8 ) JUNDER JOE BASBAS DE GUZMAN and ) 9 SONIA CAMACHO DE GUZMAN, ) ) 10 ___________________D_e_f_e_n_d_a_n_t_s_.__) 11 12 OPINION ON FEES UNDER CALIFORNIA CIVIL CODE § 1717 13 CHRISTOPHER KLEIN, Bankruptcy Judge: 14 Artful pleading in order not to state a contract cause of 15 action in a bankruptcy dischargeability case does not necessarily 16 insulate against exposure to prevailing party attorney’s fees for 17 actions “on a contract” under California Civil Code § 1717. 18 The victorious defendant in a nondischargeability action 19 seeks attorney’s fees based on the reciprocal prevailing party 20 fee provisions of California Civil Code § 1717. 21 A business divorce agreement between 50 percent shareholders 22 of a business required Defendant to pay Plaintiff $275,000, 23 consisting of $137,500 cash and $137,500 backed by a note and 24 deed of trust on Defendant’s home to be recorded after the cash 25 payment was made. The Shareholder Buyout Agreement required, 26 pursuant to Joint Escrow Instructions, the executed Deed of Trust 27 (“DOT”) to be held in trust and not recorded until Defendant 28 raised the $135,000 cash component by refinancing his home. 1 The DOT was not recorded for a year after the refinancing. 2 In the interval before recording, another DOT was recorded, 3 leaving Plaintiff under-secured when he eventually initiated the 4 foreclosure proceedings that precipitated this chapter 7 case. 5 Plaintiff sought to except the debt from discharge under 11 6 U.S.C. §§ 523(a)(2) and (a)(6), alleging fraud and willful and 7 malicious conduct in deferring recording of the DOT until after 8 obtaining other secured debt senior in position to Plaintiff. 9 The Note and DOT each have attorney’s fee provisions that 10 the victorious Defendant now invokes under the reciprocal fee 11 provision of California Civil Code § 1717. 12 13 I 14 California Civil Code § 1717 15 California’s reciprocal fee statute, as a matter of state 16 public policy, makes reciprocal all fee provisions in contracts 17 in favor of the prevailing party in litigation. The terms of the 18 contractual attorney fee provision may extend to tort and other 19 non-contract claims. In other words, all one-sided fee provisions 20 in contracts are reciprocal and entitle the prevailing party to 21 reasonable attorney fees. Cal. Civ. Code § 1717; Santisas v. 22 Goodin, 17 Cal. 4th 599, 614 (1998)(California Supreme Court); 23 Penrod v. AmeriCredit Fin. Servs. (In re Penrod), 802 F.3d 1084, 24 1088 (9th Cir. 2015). 25 The California Supreme Court has been specific that, 26 depending on the language of the particular contractual fee 27 provision, § 1717 may embrace tort and other noncontractual 28 claims. Santisas, 17 Cal. 4th at 622-23. 1 Section 1717 "was enacted to establish mutuality of remedy where a contractual provision makes recovery of attorney's fees 3 || available for only one party, and to prevent oppressive use of one-sided attorney's fees provisions." Reynolds Metals Co. v. 5] Alperson, 25 Cal.3d 124, 128 (1979). 6 7 Il 8 California Civil Code $ 1717 Applies in Bankruptcy 9 It is settled that California Civil Code § 1717 applies in 10 | bankruptcy when state law issues are integral to the bankruptcy 11] litigation. Heritage Ford v. Baroff (In re Baroff), 105 F.3d 439, 12] 442 (Sth Cir. 1997); Merced Proc. Credit Ass’n v. Sparkman (In re 13] Sparkman), 703 F.2d 1097, 1099-1100 (9th Cir. 1983). 14 That applicability, however, was formerly circumscribed in 15 the Ninth Circuit to exclude litigation in which the court 16 || decided only federal bankruptcy law issues. Fobian v. W. Farm 17 || Credit Bank (In re Fobian), 951 F.2d 1149, 1153 (9th Cir. 1991). 18 The United States Supreme Court disapproved the Ninth 19] Circuit Fobian rule in 2007 in Travelers Casualty & Surety Co. v. 20 || Pacific Gas & Electric Co., 549 U.S. 443, 452 (2007). 21 In rejecting Fobian, the Supreme Court held that claims 22} enforceable under applicable state law will be allowed in 23} bankruptcy unless they are expressly disallowed. It reasoned that 24 the validity of creditor claims in bankruptcy is ordinarily a 25 question of state law and “we generally presume that claims 26 enforceable under applicable state law will be allowed in 27 | bankruptcy unless they are expressly disallowed.” In particular, 28} it held that nothing in the Bankruptcy Code expressly disallows

claims for attorney's fees simply because the fees are incurred 2] litigating questions of federal bankruptcy law. Travelers, 549 at 452-53. 4 A consequence of Travelers is that California Civil Code S$ 1717 applies in all bankruptcy litigation when a party prevails in an action “on a contract” and otherwise satisfies the 7i}essential elements of that statute. Penrod, 802 F.3d at 1088. 8 In Penrod, the bankruptcy court had rejected § 1717 fees because enforcement of the subject contract had been defeated 10 under bankruptcy law, rather than non-bankruptcy law. The Ninth 11 |} Circuit reversed, noting that the “bankruptcy court’s reasoning 12 1 might have been valid before the Supreme Court” decided 13] Travelers, but not thereafter. Penrod, 802 F.3d at 1088. 14 The Ninth Circuit in Penrod explained that after Travelers, 15 |] the question is whether § 1717 categorically precludes awards of attorney’s fees when a party successfully limits enforcement of a 17 |} contract solely on the basis of bankruptcy law. It then answered 18 | the question in the negative, concluding that California fee- 19] shifting statutes, such as § 1717, apply to issues litigated 20 |} under bankruptcy law. Penrod, 802 F.3d at 1189. 21 In short, § 1717 applies to bankruptcy litigation when the 22 \|/essential elements for that statute are satisfied. 23 24 Til 25 Essential Elements of Civil Code § 1717 26 The three essential elements for Civil Code § 1717 attorney fee awards are: (1) an action “on a contract”; (2) a clause in 28 | the contract providing for fees; and (3) the movant must have

been the prevailing party. Penrod, 802 F.3d at 1088 (citing 2 | California law). 3 4 5 First Essential Element: “On A Contract.” 6 As a matter of California law, the term action “on a 7 || contract” is liberally construed to extend to any action, as long it "involves" a contract and one of the parties would be entitled to recover attorney fees under the contract if that 10} party prevails in its lawsuit. In re Tobacco Cases I, 193 Cal. 11] App. 4th 1591, 1601 (2011), cited by Penrod, 802 F.3d at 1087. 12 13 14 As applied in bankruptcy, an action in bankruptcy court is 15 ]} “on a contract” for purposes of § 1717 if the bankruptcy court 16 || needed to determine enforceability of the agreement in order to 17 || determine dischargeability. Conversely, if the court did not need 18 || to determine whether the agreement is enforceable, then it is not 19 an action “on a contract.” Penrod, 802 F.4th at 1088-89 (noting 20 || effect of Travelers); Bos v. Bd. of Trs., 818 F.3d 486, 489-90 21 (9th Cir.

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Related

Sparkman v. Sparkman
703 F.2d 1097 (Ninth Circuit, 1983)
Reynolds Metals Co. v. Alperson
599 P.2d 83 (California Supreme Court, 1979)
Marlene Penrod v. Americredit Financial Services
802 F.3d 1084 (Ninth Circuit, 2015)
Gregory Bos v. Board of Trustees
818 F.3d 486 (Ninth Circuit, 2016)
Spencer v. Anderson
222 P. 355 (California Supreme Court, 1924)
Santisas v. Goodin
951 P.2d 399 (California Court of Appeal, 1998)

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Sibayan v. De Guzman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sibayan-v-de-guzman-caeb-2025.