FACTS:
Atty. Socrates G. Maranan (Atty. Maranan) filed a criminal complaint before the Ombudsman against then Vice Mayor Francisco "Isko Moreno" Domagoso (Domagoso) of the City of Manila, accusing him of Falsification of Public Documents and violation of Republic Act No. 3019. Atty. Maranan alleged that Domagoso signed consultancy contracts on behalf of the Manila City Government with individuals who were either deceased or out of the country for extended periods of time. Domagoso defended himself by claiming that he relied on the assurance of his former Secretary that everything was in order, and pointed out that it was Atty. Maranan who notarized the subject contracts. The Ombudsman dismissed the charges against Domagoso and referred the matter to the Integrated Bar of the Philippines (IBP) to determine Atty. Maranan's administrative liability for notarizing the consultancy contracts. Atty. Maranan denied authoring or notarizing the contracts, citing discrepancies between his alleged signatures in the contracts and his signatures submitted to the Notarial Section of the Court. The Investigating Commissioner initially recommended the dismissal of the case for lack of evidence, but the IBP Board of Governors reversed the recommendation and found that Atty. Maranan violated the 2004 Notarial Rules. The IBP Board recommended his suspension from the practice of law, disqualification from being commissioned as a notary public, and the revocation of his current notarial commission. Atty. Maranan's motion for reconsideration was denied. The issue before the Court is whether or not Atty. Maranan can be held administratively liable.
ISSUES:
- Whether or not grounds exist to hold Atty. Maranan administratively liable.
RULING:
- Yes, grounds exist to hold Atty. Maranan administratively liable. The IBP Board of Governors found that there was substantial evidence to prove that Atty. Maranan violated the 2004 Notarial Rules, considering that it was his responsibility to impose safeguards against the unauthorized notarization of documents in his register. Despite the disparity in the signatures appearing in the consultancy contracts and his signatures in the facsimile of signatures submitted to the Notarial Section of the RTC, Atty. Maranan cannot sever himself from the supposed notarized documents as the same bore his notarial seal. Thus, the IBP recommended that Atty. Maranan be suspended from the practice of law for a period of six (6) months, disqualified from being commissioned as a notary public for a period of two (2) years, and his current notarial commission be immediately revoked.