A lawyer was suspended by the Supreme Court (SC) from the practice of law for six months for notarizing a document without the personal appearance of the person who executed and signed it.
Records showed the suspended lawyer was Arnulfo H. Manigos, according to the SC’s resolution under Administrative Case No. 7941, made public on 17 September.
The SC said, aside from suspension, it also revoked Manigos’s notarial commission and barred him from being commissioned as a notary public for two years.
In a resolution written by Chief Justice Alexander G. Gesmundo dated July 29, 2025, the SC – reiterating previous rulings – stressed that “notarization is not an empty, meaningless, and routinary act.”
The high court highlighted 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.”
It also emphasized 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 is “the personal appearance by the person or persons who execute and sign the document or instrument before the notary public.”
Further, the court explained that personal appearance “is the most effective way of ascertaining the authenticity of the document or instrument presented for notarization because the very person who executed or signed the same personally assures the notary public of their actual participation therein and of the authenticity of their signatures.”
The administrative case against Manigos was filed by Macario V. Mina, who also charged two other lawyers. However, the SC dismissed the complaints against the two lawyers due to Mina’s failure to substantiate his allegations.
Mina claimed that Manigos notarized an instrument titled “Verification/Certification” on May 16, 2006, without requiring one of the authors, Ernesto Velasco, to personally appear. Velasco could not have appeared as he had traveled to the United States on May 12, 2006, and submitted the document notarized by Manigos along with a certification from the Bureau of Immigration confirming his travel.
Manigos admitted notarizing the document without Velasco’s presence but argued he should not be penalized for assisting his long-time clients, the Velascos, to timely file their answer. He added that he notarized the document after being assured by Velasco’s wife that her husband had signed it, and claimed that his actions did not cause any harm to Mina.
The Integrated Bar of the Philippines’ Board of Governors affirmed the findings of its investigating commissioner but reduced the recommended penalty from one year to three months’ suspension of Manigos.
The SC, which has the power to discipline all lawyers, upheld the findings but modified the suspension. It emphasized that familiarity with Velasco’s signature and assurances from his wife “do not justify the non-compliance of personal appearance mandated by the Notarial Rules.”
The Court added, “Manigos's 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 Court finds Arnulfo H. Manigos guilty of violating the 2004 Rules on Notarial Practice.