Can a failure to provide competent representation in a civil or criminal case be a basis for civil liability?

" 'The failure to provide competent representation in a civil or criminal case may be the basis for civil liability under a theory of professional negligence. In a legal malpractice action arising from a civil proceeding, the elements are (1) the duty of the attorney to use such skill, prudence, and diligence as members of his or her profession commonly possess and exercise; (2) a breach of that duty; (3) a proximate causal connection between the breach and the resulting injury; and (4) actual loss or damage resulting from the attorney's negligence.' (Coscia v. McKenna & Cuneo (2001) 25 Cal.4th 1194, 1199.)