Saturday, February 21, 2009

NUNGA VS. VIRAY 306 SCRA 487



FACTS:
Victor Nunga, president of the Masantol Rural Bank filed a complaint for disbarment against Atty. Viray on the ground of gross and serious misconduct for notarizing documents when he was not commissioned to do so at the time the said documents were executed.


ISSUE: Whether or not the respondent’s act is a valid ground for disbarment.


HELD: Yes. Where the notarization of a document is done by a member of the Philippine Bar at a time when he has no authorization or commission to do so, the offender may be subjected to disciplinary action. For one, performing a notarial without such commission is a violation of the lawyer’s oath to obey the laws, more specifically, the Notarial Law. A notarial document is by law entitled to full faith and credit upon its face. For this reason, notaries public must observe with utmost care the basic requirements in the performance of their duties.

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