Maganda engaged Atty. Malakas to prepare and notarize a Special Power of Attorney (SPA) authorizing Matinik to sell portions of Maganda’s property. Unknown to Maganda, the SPA contained provisions giving Matinik authority to execute transfers of rights over the property, which Maganda had never authorized. Maganda refused to sign the SPA and asked Atty. Malakas to revise it. Despite her refusal, Atty. Malakas proceeded to notarize the SPA. Several years later, portions of Maganda’s property were transferred to Atty. Malakas’s wife and two sons. When Maganda discovered the transactions, she filed civil and criminal cases questioning the validity of the SPA and the subsequent transfers. Atty. Malakas thereafter agreed to represent Matinik, the person who had used the SPA to effect the transfers, in the cases filed by Maganda. Maria also filed an administrative complaint against Atty. Malakas for violation of the Code of Professional Responsibility and Accountability (CPRA) and the Rules on Notarial Practice.

Did Atty. Malakas violate the CPRA? (Bar 2026 Syllabus)