A.C. No. 12071 - Parungao vs. Lacua

In 2007, Mary Grace Parungao introduced Jonathan C. Parungao to Atty. Dexter B. Lacuanan, who thereafter acted as counsel in various matters involving Jonathan alone or both spouses.
In 2008, Jonathan consulted Lacuanan on collection of a P-payment and paid a P3,000 professional fee.
In 2009, Lacuanan prepared a P5,000 retainer proposal for Jonathan’s Chevron dealership application, though the agreement did not materialize.
In March–May 2011, the Spouses secured Lacuanan’s services for the purchase of a Metrobank lot: he drafted the Deed of Absolute Sale (May 13, 2011), verified a writ of possession at RTC Quezon City Branch 96, and billed P2,000 per court appearance.
On November 2, 2011, Lacuanan drafted and signed, on his letterhead, a demand letter for Jonathan against Remedios S. Espela to recover P35,000 for repairs or full refund upon return of a defective Toyota Fortuner.

Beyond professional ties, Jonathan and Lacuanan dined together, visited Jonathan’s showroom, and Jonathan allegedly confided personal and marital details.
By February 2013, Jonathan’s marriage with Mary Grace was troubled; Jonathan was later served subpoenas for preliminary investigations (May 22 and June 6, 2013) on criminal charges filed by Mary Grace.

Lacuanan appeared as counsel for Mary Grace in the May–June 2013 criminal hearings; in August 2013 Mary Grace, through Lacuanan, filed a petition for nullity of marriage (R-QZN-13-02668 RTC Quezon City Branch 107).
On March 21, 2014, Jonathan filed a disbarment complaint (CBD No. 13-4044) against Lacuanan for representing conflicting interests in violation of Canons 15.03 and 17 CPR, the Lawyer’s Oath, and Section 20, Rule 138, arguing no severance of attorney-client ties and unauthorized use of confidences.

The IBP’s Investigating Commissioner recommended dismissal (May 19, 2014).
The IBP Board of Governors reversed, finding Lacuanan guilty of conflict of interest and suspending him for one month (Apr 19, 2015; Extended Resolution Aug 11, 2016; MR denied Apr 20, 2017).
The Supreme Court granted Lacuanan’s petition and resolved to dismiss Jonathan’s complaint (Mar 11, 2020).

Whether Atty. Lacuanan represented conflicting interests by acting as counsel for Mary Grace against his former client Jonathan, in violation of Canon 15.03 and Canon 17 of the CPR, the Lawyer’s Oath, and Section 20, Rule 138.
Whether any existing attorney-client relationship or confidential information persisted in 2013 such that Lacuanan’s representation of Mary Grace constituted adverse representation.
Whether Jonathan discharged his burden to prove that Lacuanan acquired and used confidential information to Mary Grace’s advantage in the criminal and civil proceedings.