G.R. No. A.C. 7023. March 30, 2006
Bun Siong Yao, Complainant, vs. Atty. Leonardo A. Aurelio, Respondent.

FACTS

Complainant Bun Siong Yao alleged that since 1987, respondent Atty. Leonardo A. Aurelio served as his personal lawyer and as retained counsel and stockholder for two corporations where complainant was a majority stockholder. In 1999, a disagreement arose between respondent and complainant’s wife. Respondent subsequently demanded the return of his investment and, upon refusal, initiated eight criminal charges for estafa and falsification against complainant, his wife, and other corporate officers. He also filed multiple administrative complaints against them before various city prosecutors’ offices for alleged violations of the Corporation Code and SEC reportorial requirements. Complainant contended these suits constituted harassment and an abuse of confidential information acquired by respondent in his capacity as counsel, representing conflicting interests by suing his own clients and the corporations he represented.
Respondent countered that by 1999, he was no longer counsel for complainant or the corporations, having only previously handled isolated labor cases. He asserted he filed the complaints in his capacity as a stockholder after being denied access to financial statements, discovering alleged irregularities including unrecorded assets and falsified documents. He denied using any confidential attorney-client information, relying solely on data obtained as a stockholder.

ISSUE

Whether respondent violated the Code of Professional Responsibility by representing conflicting interests and engaging in unethical conduct.

RULING

Yes, respondent is administratively liable. The Court affirmed the IBP’s findings and recommended six-month suspension. The professional relationship between complainant and respondent was extensive, predating the corporations and involving personal legal services, incorporation matters, and regular counsel work, establishing an attorney-client relationship. Rule 15.03 of the Code of Professional Responsibility prohibits a lawyer from representing conflicting interests, and the duty of confidentiality to a former client is perpetual. By filing multiple suits against his former client and the corporations he previously served, respondent inevitably exploited information gained from that fiduciary relationship for personal grievance, breaching confidentiality and fairness.
Furthermore, respondent’s act of filing identical charges in different prosecutorial offices constituted forum-shopping, demonstrating an intent to harass rather than legitimately pursue a cause. This conduct exploited his legal knowledge to exact vengeance, violating the fundamental duty of lawyers to uphold the integrity and dignity of the legal profession. His actions betrayed the trust inherent in the attorney-client relationship and warranted disciplinary sanction to protect public confidence in the bar.