Oct 13, 2020 @ 13:13

SC suspends Isabela lawyer for notarizing incomplete document, making secretary record entries

The Supreme Court (SC) has suspended abogado Hipolito Salatan from the practice of law for one year after finding him guilty of notarizing an incomplete, undated document and making his secretary record the entries in his notarial register.

In a recent 7-page decision, the SC 2nd Division also revoked Salatan’s notarial commission and perpetually disqualified him from being reappointed as notary public for violation of the 2004 Rules on Notarial Practice and the Code of Professional Responsibility (CPR).

Salatan was found to have affixed his official signature and seal on the notarial certificate of the affidavit of a certain Teresita Cauilan, which was introduced as evidence by the plaintiff that he represented in a civil case before the Santiago City, Isabela, Regional Trial Court (RTC) Branch 36.

The defendant, Valentino Leano, complained that there were several defects in the affidavit.

The SC noted that Salatan did not properly identify the person who signed the document, as the competent proof of Cauilan’s identity was left blank. It said he completely failed to explain why the proof of identity was not indicated in the notarial certificate.

It added that the affidavit was not recorded in Salatan’s notarial register, in violation of Section 2(a), Rule VI of the Notarial Rules. He merely cited “oversight” and pointed out that there was vacant space in the notarial register that was intended for the document.

“A notary public is personally accountable for all entries in his notarial register,” stressed the decision penned by Associate Justice Henri Jean Paul Inting.

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