J.A.B. Bulao & Associates

CASE 2020-30: VALENTINO C. LEANO VS. ATTY. HIPOLITO C. SALATAN (A.C. NO. 12551, JULY 8, 2020, INTING, J.) (SUBJECT/S: NOTARIAL PRACTICE)

DISPOSITIVE:

“WHEREFORE, The Court finds respondent ATTY. HIPOLITO C. SALATAN GUILTY of violating the 2004 Rules on Notarial Practice and the Code of professional Responsibility.  Accordingly, his Notarial Commission, if still existing, in REVOKED, and he is hereby PERPETUALLY DISQUALIFIED  fron being reappointed as Notary Public. Respondent ATTY. HIPOLITO C. SALATAN is likewise SUSPENDED from the practice of law for a period of I (1 ) year effective immediately.

Let copies of this DECISION be furnished the Office of the Bar Confidant to be appended to Responded ATTY. HIPOLITO C. SALATAN personal record, and the Office of Court Administrator and the Integrated Bar of the Philippines for their information and guidelines.

So Ordered.”

SUBJECTS/DOCTRINES/DIGEST:

THE NOTARY PUBLIC LEFT BLANK THE PROOF OF IDENTITY ON THE NOTARIZED DOCUMENT. THIS PROVES THAT THE NOTARY PUBLIC DID NOT PROPERLY IDENTIFY THE PERSON SIGNING THE NOTARIZED DOCUMENT.

WHAT SHOULD HAVE BEEN THE REMEDY?

IT APPEARS FROM THE DECISION THAT THERE SHOULD BE AN ALLEGATION THAT THE PERSON SIGNING THE DOCUMENT IS PERSONALLY KNOWN TO THE NOTARY PUBLIC. THE REQUIREMENT OF COMPETENT PROOF OF IDENTITY MAY BE DISPENSED WITH.

THE NOTARY PUBLIC DELEGATED THE RECORDING OF HIS NOTARIZED DOCUMENTS IN THE NOTARIAL REGISTER. IS THIS PROPER?

NO BECAUSE A NOTARY PUBLIC IS PERSONALLY ACCOUNTABLE FOR ALL ENTRIES IN HIS NOTARIAL REGISTER.

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