G.R. No. 267487 - Jose P. Singh vs. Perfecto S. Corpus, Jr. and Marlene S. Corpus

Petitioner Jose P. Singh filed a Petition for Review on Certiorari assailing the Court of Appeals decision affirming a finding of malicious prosecution against him.
Respondents are Atty. Perfecto S. Corpus, Jr. and Marlene S. Corpus, who filed a complaint for damages against Singh.
The complaint arose from a disbarment case Singh filed against Atty. Corpus, alleged to be baseless and malicious.

In May 2014, Singh met Atty. Corpus and expressed his intent to discharge his counsel in Civil Case No. 07-09-3871, which concerns a 5,309-square meter property in Tanauan City, Batangas.
Singh was represented by Atty. Gino Jacinto of Quicho and Angeles Law Offices but was dissatisfied due to a unilateral increase in attorney’s fees.
Singh engaged Atty. Corpus as his new counsel in June 2014, paying a PHP 30,000 acceptance fee.

Atty. Corpus discussed legal strategies and worked on the case, attending meetings and studying pertinent facts and jurisprudence.
On June 20, 2014, Singh instructed Atty. Corpus to suspend work on Civil Case No. 07-09-3871 and requested him to handle another complex case, which Atty. Corpus declined.
By letter dated June 30, 2014, Singh terminated their retainer agreement and demanded the return of the PHP 30,000 acceptance fee. Atty. Corpus refused to return the fee, explaining that work had already commenced.
Singh accused Atty. Corpus of immorality for refusing to return the money and threatened to file a disbarment complaint.

Singh filed the disbarment complaint docketed as A.C. No. 10529, alleging negligence for failure to render services and unethical conduct for refusing to return the fee and furnishing copies of his reply letter to third parties.
On March 5, 2018, the Supreme Court dismissed the disbarment complaint for lack of merit, citing insufficient evidence of violations and recognizing the acceptance fee as generally non-refundable due to the opportunity cost incurred by the lawyer.
The Court emphasized its duty to protect the reputation of lawyers frivolously or maliciously charged.

Atty. Corpus filed a complaint for damages asserting that the malicious disbarment complaint tarnished his 35-year reputation as a private practitioner and former judge and affected his law practice and notary public application.
Singh and his counsel failed to appear at the pre-trial conference; hence, the trial court allowed Atty. Corpus to present evidence ex parte.
The Regional Trial Court found Singh and his spouse jointly and severally liable for moral damages of PHP 300,000, exemplary damages of PHP 200,000, attorney’s fees of PHP 100,000, and costs amounting to PHP 17,360.
The Court of Appeals affirmed with modification, holding that Singh had filed a baseless and malicious disbarment complaint to vex Atty. Corpus because of the refusal to return the acceptance fee, which was non-refundable and justified.

Singh contests the ruling, arguing no proof was presented of reputation damage, and the filing of the disbarment complaint should not be considered malicious prosecution.
He reiterates that refusing to return the PHP 30,000 acceptance fee was immoral.

Whether the filing of the disbarment complaint by Singh against Atty. Corpus constituted malicious prosecution.
Whether the PHP 30,000 acceptance fee paid to Atty. Corpus was refundable.
Whether Atty. Corpus is entitled to moral, exemplary damages, attorney’s fees, and costs for the malicious prosecution.
Whether Singh’s spouse should be held liable for damages.
The proper quantum of damages to be awarded.