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,
Related reading
The Supreme Court rules that the COA cannot reverse a final decision absolving employee-recipients from refunding disallowed benefits, reinforcing finality principles.
The Supreme Court reinstates wage claims of OFWs against a recruitment agency, ruling that forged payrolls cannot defeat workers' right to just compensation.
The Supreme Court clarifies when a "conditional sale" is really a contract to sell, and warns against forum shopping in property disputes.
The Supreme Court acquits a barangay kagawad of graft, clarifying the elements of Section 3(c) of RA 3019 and the importance of substantial justice over technical rules.
Have a question about this topic?
This article is general information, not legal advice. Ask ASG Legal AI for a cited, plain-language answer on your own situation — free, no sign-up.