THE Supreme Court (SC) has suspended a lawyer for six months and prohibited him from being commissioned as a notary public for two years after he notarized a document without requiring one of the signatories to personally appear before him.
Lawyer Arnulfo Manigos was found guilty of violating the 2004 Rules on Notarial Practice and was thus barred from acting as a notary for two years.
The complaint against Manigos stemmed from the disbarment cases Macario Mina lodged against Manigos and lawyers Florencio Anchuvas and Roberto Arca on the grounds that they committed falsehood and had intentionally misled the court.
But the High Court, in an 11-page ruling promulgated on July 29, 2025, dismissed the case against Anchuvas and Arca on account of the petitioner’s failure to substantiate his claim.
But it found Manigos guilty and suspended him from law practice for six months.
Concurring with the ruling were Associate Justices Ramon Paul Hernando, Rodil Zalameda, Jose Midas Marquez, and Ricardo Rosario.
“The requirement of 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 signature,” said the ruling that Chief Justice Alexander Gesmundo wrote.
The High Court stressed that the requirement of personal appearance by the person who executed and signed the document should not be taken lightly and must be faithfully observed by the notary public to help attain the overall objective of the Notarial Rules.
“Here, respondent Manigos categorically admitted that he notarized the verification and or certification in the absence of Velasco, thus directly contravening the aforequoted provision of the Notarial Rules,” it added.
Likewise, the High Court said it is not persuaded by Manigos’ Defense that he merely accommodated his long-time clients so that they would not be declared in default for failure to file an answer.
“Respondent 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,” it added.
Aside from suspending Manigos, the high court also prohibited him from being commissioned as a notary public for a period of two years and warned him that a repeat of the offense would be dealt with more severely.
