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SC suspends lawyer for violation of rule in notarizing document

September 30, 2025

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Manila Bulletin

The Supreme Court (SC) has suspended a lawyer from the practice of law for six months for notarizing a document without the personal appearance of the person who executed and signed the document.

- By REY G. PANALIGAN

Suspended was lawyer Arnulfo H. Manigos in the SC's resolution under Administrative Case No. 7941 which was made public last Sept. 17.

Aside from suspension, the SC also revoked Manigos's notarial commission, and banned him from being commissioned as a notary public for two years.

In a resolution written by Chief Justice Alexander G. Gesmundo, the SC - reiterating previous rulings - stressed that "notarization is not an empty, meaningless, and routinary act."

It pointed out that notarization "is invested with substantive public interest as it has the effect of converting a private instrument into a public document," which, in turn, "is admissible in evidence without need of first proving its authenticity."

Thus, it stressed that "a notarized document is, by law, entitled to full faith and credit upon its face."

To preserve the integrity of notarized documents, the SC said one of the most fundamental requirements in notarization "is the personal appearance by the person or persons who execute and sign the document or instrument before the notary public."

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