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SC suspends lawyer over backdated election docs
The Comelec found that the forms used were issued only in 2013, raising questions about the authenticity of the purported filing date.
The Supreme Court (SC) has suspended lawyer Paisal Padate from practicing law for one year and barred him from notarizing documents for two years after finding him liable for notarizing backdated campaign expense reports for a political candidate.
In a decision dated 26 August 2026 and recently made public, the high court en banc also revoked Padate’s existing notarial commission.
The disciplinary case stemmed from a complaint filed by the Commission on Elections’ Campaign Finance Office over the Statement of Contributions and Expenditures and Schedule of Expenditures submitted for candidate Amer-Ali Mangandog.
The documents bore Padate’s notarial seal dated June 2010. However, the Comelec found that the forms used were issued only in 2013, raising questions about the authenticity of the purported filing date.
Padate denied any wrongdoing, claiming unidentified individuals had forged his signature, duplicated his official seal and used his credentials without authorization. He also argued that there was no proof he personally notarized the documents.
The Supreme Court rejected his defense, ruling that he had failed to substantiate his allegation of forgery.
“His uncorroborated assertions do not overcome the evidentiary weight of the documents bearing his commission details and signature as notary public,” the court said.
The justices found that the discrepancy between the documents’ purported execution date and the issuance of the forms constituted deliberate misrepresentation and violated notarial practice rules.
The court also noted that the notarial certificates lacked competent evidence of identity and that the docket numbers on the documents appeared irregular and inconsistent, raising concerns about the integrity of Padate’s notarial register.
His actions demonstrated “marked indifference” to the requirements of notarial practice, the court said, warning that such irregularities undermine the authenticity and reliability of notarized documents and erode public confidence in the notarial system.