The Supreme Court (SC) has affirmed the award of damages to a lawyer who was maliciously prosecuted by his client by filing a disbarment case for not returning the acceptance fee paid for handling a case.

In a decision that affirmed with modification the ruling of the Court of Appeals (CA), the SC ordered Jose P. Singh to pay Atty. Perfecto S. Corpus P30,000 as moral damages, P20,000 as exemplary damages, P10,000 as attorney’s fees, and P17,360 as cost of suit for malicious prosecution.

The SC’s decision, which was made public on March 1, 2024, was written by Associate Justice Amy C. Lazaro Javier.

In May 2014, Corpus and Singh met in Makati City.  Singh told Corpus that he was inclined to discharge the services of his lawyer in a civil case involving 5,309-square-meter lot in Tanauan City in Batangas. Singh said he was one of the defendants in the civil case.

On June 9, 2014, Singh told Corpus that he tried to communicate with his lawyer who was unresponsive.  Singh engaged the services of Corpus who asked an acceptance fee of P30,000 which was paid on June 11, 2014.

On June 14, 2014, Corpus accompanied Singh to Canyon Woods Properties in Taal, Batangas where they discussed again the latter’s civil case in Tanauan City.  When Corpus inquired about the case records, Singh said the documents were still with his former lawyer.

In a letter dated June 18, 2014, Singh asked Corpus to examine a draft of Secretary's Certificate and Special Power of Attorney on the Tanauan City case.

But on June 20, 2014, Singh instructed Corpus to hold in abeyance all work in the Tanauan City civil case and asked the latter to handle instead a case involving residents of Canyon Woods.  Corpus declined because of the complexity of the Canyon Woods case.

In a letter dated June 30, 2014, Singh told Corpus he was terminating the latter’s services and demanded that the P30,000 he paid as acceptance fee be returned.

In his reply, Corpus agreed to the termination of his legal services but declined to return the P30,000. He said he has started his work by conducting extensive study on the facts, related laws, and jurisprudence relative to the Tanauan City case and has attended several meetings.

On July 4, 2024, Singh sent Corpus another letter and called him “immoral” for refusing to return the P30,000 “entrusted money.”  He threatened to file a disbarment case against Corpus.

Corpus explained that the money was not “entrusted money” but payment for his acceptance fee.  His letter to Singh was furnished his client’s previous counsel and his wife, Adelia Singh.

Singh filed a disbarment case against Corpus who was accused of failure to render any legal service and unethical conduct for giving copies of the latter’s letter to the former’s lawyer and his wife.

On March 5, 2018, the SC dismissed the disbarment complaint against Corpus.  The SC ruled that Singh failed to adduce sufficient evidence concerning Atty. Corpus's alleged infraction of the Lawyer's Oath and the then Code of Professional Responsibility.

The SC also pointed out that the records of the case did not show Corpus was impelled by any ulterior motive when he furnished copies of his Letter-Reply to Singh's wife, and his former counsel.

On the acceptance fee, the SC adopted the report of the Integrated Bar of the Philippines that the fee refers to the charge imposed by the lawyer for merely accepting the case.

Thus, by accepting the Tanauan City case from Singh, Corpus incurred an opportunity cost since he was precluded from handling cases of the opposing party based on the prohibition against the conflict-of-interest rule, the SC said.

It pointed out that “the duty of the Court towards members of the bar is not only limited to the administration of discipline to those found culpable of misconduct but also to the protection of the reputation of those frivolously or maliciously charged.”

Corpus then filed a malicious prosecution charge against Singh and his wife. He told the Paranaque City regional trial court (RTC) the filing of a baseless disbarment case against him tarnished his reputation as a lawyer for 35 years and as former trial court judge in Pampanga.

On Oct. 16, 2020, the Paranaque City regional trial court (RTC) ordered the Singh spouses to pay Corpus P300,000 as moral damages, P200,000 as exemplary damages, P100,000 as attorney’s fees, and P17,360 as cost of suit.

The CA affirmed the RTC’s ruling.  Singh elevated the case to the SC.

Dismissing Singh’s petition, affirming the damages for malicious prosecution, and modifying the CA’s ruling, the SC said:

“Thus, we reduce the damages granted to Atty. Corpus to P30,000 as moral damages, P20,000 as exemplary damages, and P10,000 as attorney's fees. We retain the payment of P17,360.00 in favor of Atty. Corpus as cost of suit. Ali monetary awards are subject to 6% interest per annum from finality of this Decision until fully paid.”