Lawyer Suspended for Notarization Violation; SC Upholds Personal Appearance

Lawyer Suspended for Notarization Violation; SC Upholds Personal Appearance

By Bing Jabadan – TheNationWeek.Com | October 2, 2026

MANILA, Philippines – The Supreme Court (SC) has handed down a six-month suspension to a lawyer for violating a fundamental principle of notarial practice: the requirement of personal appearance.

The ruling, made public on Sept. 17 under Administrative Case 7941, also revokes Arnulfo Manigos’ notarial commission and bars him from reapplying for two years.

The case stemmed from a complaint filed by Macario Mina, alleging that the lawyer notarized a “verification/certification” document on May 16, 2006, without the presence of one of the signatories, Ernesto Velasco.

Mina presented evidence, including a Bureau of Immigration certification, proving that Velasco had traveled to the United States four days before May 12, 2006.

In his defense, Manigos admitted to notarizing the document in Velasco’s absence, claiming he did so to assist his long-time clients, the Velasco spouses, in meeting a filing deadline.

He added that Velasco’s wife assured him the document was signed by her husband and that his actions caused no harm to Mina.

However, the high court, in a resolution penned by Chief Justice Alexander Gesmundo, rejected the justifications.

The SC stressed the critical role of notarization in transforming private documents into public instruments, granting them admissibility in court without requiring proof of authenticity.

“Notarization is not an empty, meaningless, and routinary act,” the resolution stated.

“It is invested with substantive public interest as it has the effect of converting a private instrument into a public document… a notarized document is, by law, entitled to full faith and credit upon its face.”

The court underscored that personal appearance is the “most effective way of ascertaining the authenticity of the document,” ensuring the signatory’s genuine participation and the legitimacy of his/her signature.

While the Integrated Bar of the Philippines (IBP) Board of Governors also found Manigos guilty, they initially recommended a shorter three-month suspension.

The SC, however, upheld the IBP’s findings but increased the penalty to six months, emphasizing the seriousness of the violation.

It stated that Manigos’ familiarity with Velasco’s signature and the assurances of Velasco’s wife did not excuse his failure to adhere to the mandatory requirement of personal appearance.

“Manigos’ zeal to advance the interests of his clients, no matter how true and commendable, is not a valid excuse to violate a clear and mandatory provision of the notarial rules,” the SC explained.

The ruling serves as a reminder to lawyers of their ethical obligations and the importance of upholding the integrity of the notarial process.

The SC warned Manigos that any repetition of similar conduct in the future would be dealt with more severely.