Notarial Misconduct Upholding Public Trust in Legal Documentation
A notary who acts outside her commission undermines public trust. The Court fined a lawyer P10,000 for notarizing documents in Bayombong without authority.
Notarization is not an empty, routinary act. It is invested with substantive public interest. In Maddela v. Dallong-Galicinao (A.C. No. 6491, January 31, 2005, 490 Phil. 437), the Supreme Court reminded all notaries public — lawyers or otherwise — that acting beyond the area of one's notarial commission is misconduct that invites discipline, even if done for free or as a favor.
The Case
Complainant Benilda Maddela was a clerk in the Office of the Clerk of Court, Regional Trial Court (RTC), Bayombong, Nueva Vizcaya. Respondent Atty. Rosalie Dallong-Galicinao was the Clerk of Court and Ex-Officio Provincial Sheriff of the RTC, Bambang,
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