ASG Law

Tag: Document Notarization

  • Notarial Practice: Lawyer Liability for Improper Document Notarization in the Philippines

    Notaries Beware: Due Diligence is Key to Avoiding Disciplinary Action

    A.C. No. 13557 [Formerly CBD Case No. 14-4293], October 04, 2023

    The integrity of the notarial process is paramount in the Philippines, as notarization imbues private documents with public trust and evidentiary weight. But what happens when a notary public fails to exercise due diligence and notarizes documents based on insufficient identification, or worse, when the person presenting the document is already deceased? The Supreme Court recently addressed this issue in the case of Dominador C. Fonacier v. Atty. Gregorio E. Maunahan, highlighting the significant consequences for lawyers who neglect their notarial duties. This case underscores the importance of strict adherence to the 2004 Rules on Notarial Practice and the newly implemented Code of Professional Responsibility and Accountability (CPRA) to safeguard the integrity of legal documents and the legal profession itself.

    The Legal Framework for Notarial Practice

    Notarization transforms a private document into a public one, making it admissible in court without further proof of authenticity. This places a heavy responsibility on notaries public to ensure the accuracy and integrity of the documents they certify. The 2004 Rules on Notarial Practice and the CPRA outline the specific duties and responsibilities of notaries in the Philippines.

    Specifically, Rule IV, Section 2(b) of the 2004 Rules on Notarial Practice states that a notary cannot perform a notarial act unless:

    (1) the person involved as signatory to the instrument or documents is in the notary’s presence personally at the time of the notarization; and (2) personally known to the notary public or otherwise identified by the notary public through competent evidence of identity.

    Competent evidence of identity, as defined by Rule II, Section 12, includes at least one current identification document issued by an official agency bearing the individual’s photograph and signature. Community Tax Certificates (CTCs) are *not* considered competent evidence of identity because they lack a photograph and signature. Moreover, the CPRA emphasizes a lawyer’s duty to uphold the law and maintain the integrity of the legal profession, including proper adherence to notarial rules.

    Hypothetical: Imagine a scenario where someone presents a photocopy of a driver’s license and a barangay clearance to a notary public, requesting notarization of a deed of sale. If the notary public proceeds with the notarization based solely on these documents, without verifying the authenticity of the driver’s license or requiring a valid government-issued ID with a photograph and signature, they could be held liable for violating notarial rules.

    Case Breakdown: Fonacier v. Maunahan

    The case of Dominador C. Fonacier v. Atty. Gregorio E. Maunahan revolves around Atty. Maunahan’s notarization of a Special Power of Attorney (SPA), Affidavit of Loss (AOL), and Verification and Certification for a petition to replace a lost title. The complainant, Fonacier, argued that the documents were falsified because the supposed principal, Anicia C. Garcia, had already passed away years before the documents were supposedly executed.

    Here’s a breakdown of the case:

    • Background: A petition was filed to replace a lost title, supported by notarized documents prepared by Atty. Maunahan.
    • The Claim: Fonacier contested the petition, stating that the principal was deceased at the time of notarization.
    • IBP Findings: The IBP initially recommended penalties against Atty. Maunahan, but later reversed its decision on humanitarian grounds.
    • Supreme Court Ruling: The Supreme Court overturned the IBP’s final recommendation, finding Atty. Maunahan administratively liable.

    The Supreme Court emphasized that Atty. Maunahan failed to exercise due diligence in verifying the identity of the person claiming to be Anicia Garcia. He relied on a CTC and a prior SPA from 1992, which did not meet the requirements for competent evidence of identity. Moreover, the Court noted that the documents were not properly recorded in Atty. Maunahan’s notarial register, further indicating a breach of notarial duties.

    The Court quoted:

    Evidently, notaries public should not notarize a document unless the person who signed the same is the very person who executed and personally appeared before them to attest to the contents and the truth of what are stated therein. This requirement, in turn, is fulfilled by the presentation by the attesting person of competent evidence of identity.

    And:

    The failure of the notary public to record the document in his notarial register is tantamount to falsely making it appear that the document was notarized when, in fact, it was not.

    The Supreme Court ultimately found Atty. Maunahan guilty of violating the 2004 Rules on Notarial Practice and the CPRA, imposing penalties including suspension from the practice of law, revocation of his notarial commission (if existing), disqualification from being commissioned as a notary public, and a fine.

    Practical Implications and Key Lessons

    This ruling serves as a stern reminder to all notaries public in the Philippines to exercise utmost diligence in performing their duties. The consequences of failing to do so can be severe, including disciplinary actions, suspension from practice, and financial penalties. The court emphasized the strict requirements for verifying the identity of individuals seeking notarization and the importance of maintaining accurate notarial records.

    Key Lessons:

    • Verify Identity Diligently: Always require competent evidence of identity, as defined by the 2004 Rules on Notarial Practice. Do not rely solely on CTCs or outdated documents.
    • Maintain Accurate Records: Ensure that all notarial acts are properly recorded in the notarial register, with all required information.
    • Stay Updated: Keep abreast of changes in notarial rules and regulations, including the new CPRA.
    • Exercise Caution: If there are any doubts about the identity of the person seeking notarization or the authenticity of the documents, refuse to perform the notarial act.

    Another Hypothetical: A real estate agent asks a notary to pre-sign several blank notarial certificates to expedite future transactions. Even if the notary trusts the agent, agreeing to this practice would be a grave violation of notarial rules and could lead to severe penalties if discovered.

    Frequently Asked Questions (FAQs)

    Q: What is competent evidence of identity for notarization in the Philippines?

    A: Competent evidence includes at least one current identification document issued by an official agency bearing the photograph and signature of the individual, such as a passport, driver’s license, or PRC ID.

    Q: Can a Community Tax Certificate (CTC) be used as the sole form of identification for notarization?

    A: No. CTCs are not considered competent evidence of identity because they do not bear the photograph and signature of the owner.

    Q: What are the penalties for violating the Rules on Notarial Practice?

    A: Penalties can include revocation of notarial commission, disqualification from being commissioned as a notary public, suspension from the practice of law, and fines.

    Q: What should a notary public do if they suspect a document presented for notarization is fraudulent?

    A: A notary public should refuse to perform the notarial act if they have any doubts about the authenticity of the document or the identity of the person seeking notarization.

    Q: Does acquittal in a criminal case related to falsification automatically clear a lawyer of administrative liability for violating notarial rules?

    A: No. Administrative proceedings are independent of criminal cases, and a lawyer can still be found administratively liable even if acquitted in a criminal case.

    Q: What is the Code of Professional Responsibility and Accountability (CPRA)?

    A: The CPRA is the new code of ethics for lawyers in the Philippines, replacing the Code of Professional Responsibility. It took effect on May 29, 2023, and governs the conduct of lawyers, including their notarial duties.

    ASG Law specializes in legal ethics and administrative law. Contact us or email hello@asglawpartners.com to schedule a consultation.

  • Notarial Law: Personal Appearance Requirement and Consequences of Non-Compliance

    The Supreme Court held that a notary public’s failure to require the personal appearance of individuals signing a document constitutes a violation of notarial law, warranting disciplinary action. This ruling emphasizes the crucial role of notaries public in ensuring the authenticity and due execution of legal documents, thereby safeguarding the integrity of public instruments. The decision serves as a stern reminder to notaries public to strictly adhere to the requirements of personal appearance to maintain public trust and confidence in the notarization process, preventing potential fraud and misrepresentation.

    The Absent Signatures: When Does Notarization Fail the Personal Appearance Test?

    This case revolves around spouses Ray and Marcelina Zialcita filing an administrative complaint against Atty. Allan Latras for violating notarial law. The spouses alleged that Atty. Latras notarized a Deed of Absolute Sale without their personal appearance, and that Atty. Latras was also legal counsel for the other party involved, Ester Servacio. The central legal question is whether a notary public can be held liable for notarizing a document without the personal appearance of the signatories, even if they claim to have relied on assurances that the parties would later appear.

    The 2004 Rules on Notarial Practice are explicit on the requirements for notarization. Section 1 of Rule II dictates that an acknowledgment requires the individual to appear in person before the notary public and present a complete document. The notary must either personally know the individual or verify their identity through competent evidence. Further, the individual must represent that their signature was voluntarily affixed for the stated purposes. These requirements ensure the integrity and authenticity of notarized documents.

    Section 2(b) of Rule IV reinforces this by prohibiting a notary public from performing a notarial act if the signatory is not personally present at the time of notarization. This rule also applies if the signatory is not personally known to the notary or identified through competent evidence. These provisions underscore the importance of personal appearance in the notarization process. The rules aim to prevent fraud and ensure that the document is executed with the full knowledge and consent of the parties involved.

    SECTION 1. Acknowledgment. – “Acknowledgment” refers to an act in which an individual on a single occasion:

    (a) appears in person before the notary public and presents an integrally complete instrument or document;

    (b) is attested to be personally known to the notary public or identified by the notary public through competent evidence of identity as defined by these Rules; and

    (c) represents to the notary public that the signature on the instrument or document was voluntarily affixed by him for the purposes stated in the instrument or document, declares that he has executed the instrument or document as his free and voluntary act and deed, and, if he acts in a particular representative capacity, that he has the authority to sign in that capacity.

    In this case, it was undisputed that Atty. Latras notarized the subject document without the spouses’ personal appearance. His defense was that he acted upon the instruction of Ray Zialcita and relied on the assurance that the spouses would appear later. The Court rejected this argument, emphasizing that substantial compliance with notarial law is insufficient when the requirement of personal appearance is not met. The Court has repeatedly stressed that personal appearance is crucial to enable the notary public to verify the genuineness of the signatory’s signature.

    The Supreme Court cited Agagon v. Bustamante, emphasizing that notarization is not a mere formality. It converts a private document into a public one, making it admissible in evidence without preliminary proof of authenticity. The court stated:

    It cannot be overemphasized that notarization of documents is not an empty, meaningless or routinary act. It is invested with substantive public interest, such that only those who are qualified or authorized may act as notaries public. It is through the act of notarization that a private document is converted into a public one, making it admissible in evidence without need of preliminary proof of authenticity and due execution. Indeed, a notarial document is by law entitled to full faith and credit upon its face, and for this reason, notaries public must observe utmost care in complying with the elementary formalities in the performance of their duties. Otherwise, the confidence of the public in the integrity of this form of conveyance would be undermined.

    Given these considerations, the Court found Atty. Latras administratively liable for notarizing the document without the required personal appearance. He could not evade responsibility by claiming that he was merely following instructions. While the complainants alleged conspiracy between Atty. Latras and Servacio to substitute the first page of the deed, they failed to provide clear and preponderant evidence to support this claim. The required quantum of proof in administrative complaints against lawyers necessitates that the evidence is clear and convincing.

    The Supreme Court, in Gonzales v. Bañares, imposed a penalty of revocation of notarial commission and suspension from the practice of law for six months for a similar violation. Furthermore, in Orola v. Baribar, the Court deemed it proper to impose the penalty of suspension from the practice of law for one year, revocation of the incumbent commission as a notary public, and disqualification from being commissioned as a notary public for a period of two years.

    Reflecting these established principles, the Court held Atty. Latras administratively liable. The penalty imposed was suspension from the practice of law for six months, revocation of his notarial commission (if currently commissioned), and disqualification from being commissioned as a notary public for two years. This ruling reinforces the judiciary’s commitment to maintaining the integrity of the notarial process and upholding the public’s trust in legal documents.

    FAQs

    What was the key issue in this case? The key issue was whether a notary public violated notarial law by notarizing a document without the personal appearance of the signatories. This raised questions about the strict adherence to procedural requirements and the consequences of non-compliance.
    What is the personal appearance requirement in notarial law? The personal appearance requirement mandates that individuals signing a document must physically appear before the notary public at the time of notarization. This allows the notary to verify the identity and genuineness of the signatory’s signature.
    Why is personal appearance important in notarization? Personal appearance is crucial because it enables the notary public to ensure that the document is executed with the full knowledge and consent of the parties involved. It also helps prevent fraud and misrepresentation by verifying the identity of the signatories.
    What are the consequences for a notary public who fails to comply with the personal appearance requirement? A notary public who fails to comply with the personal appearance requirement may face administrative sanctions, including suspension from the practice of law, revocation of their notarial commission, and disqualification from being commissioned as a notary public in the future.
    Can a notary public rely on assurances that the signatories will appear later? No, a notary public cannot rely on assurances that the signatories will appear later. The law requires that the signatories be personally present at the time of notarization to ensure the validity and integrity of the document.
    What evidence is required to prove a violation of notarial law? In administrative complaints for violations of notarial law, the required quantum of proof is clear and preponderant evidence. This means that the evidence presented must be clear, convincing, and sufficient to establish the violation.
    What is the purpose of notarization? Notarization converts a private document into a public one, making it admissible in evidence without the need for preliminary proof of authenticity and due execution. It also assures the public that the document was executed with the full knowledge and consent of the parties involved.
    What should individuals do if they suspect a notary public has violated notarial law? Individuals who suspect a notary public has violated notarial law can file an administrative complaint with the Integrated Bar of the Philippines (IBP). They should provide as much evidence as possible to support their claim.

    This case underscores the importance of strict compliance with notarial law and the consequences of failing to adhere to its requirements. Notaries public play a vital role in ensuring the integrity of legal documents, and their failure to uphold these standards can have serious repercussions. The Supreme Court’s decision reinforces the need for diligence and adherence to the rules to maintain public trust in the notarization process.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: SPOUSES RAY AND MARCELINA ZIALCITA, COMPLAINANTS, VS. ATTY. ALLAN LATRAS, RESPONDENT., A.C. No. 7169, March 11, 2019

  • Upholding Notarial Duties: Ensuring Signatory Identity and Document Voluntariness in Philippine Law

    The Supreme Court held that a notary public must ensure the personal presence and identity of the signatory to a document and verify the document’s voluntariness. Atty. Lope M. Velasco was found guilty of violating the 2004 Rules on Notarial Practice and the Code of Professional Responsibility for notarizing a document without properly identifying the signatory, Imelda Cato Gaddi, or ensuring the voluntariness of her admission. This decision underscores the importance of notarial duties in safeguarding the integrity of public documents and protecting individuals from potential coercion.

    The Case of the Dubious Document: When a Notary’s Negligence Undermines Legal Integrity

    This case revolves around Imelda Cato Gaddi’s complaint against Atty. Lope M. Velasco for allegedly violating the 2004 Rules on Notarial Practice. Gaddi claimed that Velasco notarized her handwritten admission without her personal appearance, consent, or proper identification. The central legal question is whether Velasco breached his duties as a notary public, thereby compromising the integrity of the notarized document and potentially prejudicing Gaddi’s rights.

    The facts of the case reveal a dispute within the Bert Lozada Swimming School (BLSS). Gaddi, an Operations and Accounting Manager, initiated a branch in Solano, Nueva Vizcaya, believing she had authorization. However, Angelo Lozada, the Chief Operations Officer, denied this authorization, leading to the apprehension of swimming instructors. While at the BLSS main office, Gaddi was allegedly coerced into writing an admission that the Solano branch was unauthorized. This handwritten admission was later notarized by Velasco and used against Gaddi in a complaint filed by Angelo.

    Gaddi contested the notarization, asserting she never personally appeared before Velasco, consented to the notarization, or provided any competent evidence of identity. In response, Velasco claimed Gaddi appeared before him in Makati City, presented her BLSS ID and Tax Identification Number (TIN) ID, and requested the notarization of the document. He insisted he complied with the 2004 Rules on Notarial Practice and duly recorded the notarization in his notarial register.

    The Integrated Bar of the Philippines (IBP) investigated the matter and found merit in Gaddi’s complaint. The Investigating Commissioner noted the improbability of Gaddi traveling to Makati City to notarize a self-incriminating document before heading to Nueva Vizcaya. The IBP also questioned the validity of the identification cards presented by Velasco, especially since the notarial certificate lacked the necessary details. Consequently, the IBP recommended a fine for Velasco, along with the revocation of his notarial commission and disqualification from being commissioned as a notary public for two years.

    The Supreme Court affirmed the IBP’s findings, emphasizing the critical role of notaries public in the legal system. The Court reiterated that notarization is not a mere formality but a solemn act that transforms a private document into a public one, making it admissible in evidence without further proof of authenticity. The Court emphasized the importance of notaries public adhering to the basic requirements in performing their duties.

    “Time and again, we have reminded lawyers commissioned as notaries public that notarization is not an empty, meaningless, and routinary act. Notarization converts a private document to a public document, making it admissible in evidence without further proof of its authenticity.”

    The 2004 Rules on Notarial Practice clearly outline the duties of a notary public. Rule IV, Section 2(b) requires that the signatory to the document be personally present at the time of notarization and either personally known to the notary or identified through competent evidence of identity. Rule VI, Section 3(a) mandates that the signatory sign or affix a thumb or mark in the notary public’s notarial register at the time of notarization.

    The Supreme Court found that Velasco failed to comply with these essential requirements. The notarial certificate itself indicated that spaces for the Community Tax Certificate (CTC) number and place of issuance were left blank, undermining Velasco’s claim that he properly ascertained Gaddi’s identity. This failure to ensure Gaddi’s presence made it impossible for Velasco to determine whether the handwritten admission was executed voluntarily.

    The Court also noted that Velasco did not present his notarial register to refute Gaddi’s allegations. This failure to present crucial evidence led the Court to presume that the suppressed evidence would be adverse if produced, as provided under Rule 131, Section 3(e) of the Rules of Court. The Court then cited the case of Isenhardt v. Real, where a notary public was penalized for failing to discharge his duties, emphasizing the serious consequences of neglecting notarial responsibilities.

    In Isenhardt v. Real, the notary public’s commission was revoked, and he was disqualified from being commissioned as a notary public for two years and suspended from the practice of law for one year. Similarly, in this case, the Supreme Court found that Velasco’s actions constituted a breach of Canon 1 and Rule 1.01 of the Code of Professional Responsibility. Canon 1 states that “[a] lawyer shall uphold the Constitution, obey the laws of the land and promote respect for law and legal processes,” while Rule 1.01 provides that “[a] lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.”

    Given these violations, the Supreme Court imposed a penalty commensurate with the gravity of Velasco’s misconduct. The Court not only disqualified him from being commissioned as a notary public for two years but also suspended him from the practice of law for one year. This decision serves as a stern reminder to all notaries public of their crucial role in upholding the integrity of legal documents and the importance of adhering strictly to the requirements of the 2004 Rules on Notarial Practice.

    FAQs

    What was the key issue in this case? The key issue was whether Atty. Lope M. Velasco violated the 2004 Rules on Notarial Practice by notarizing a document without ensuring the signatory’s personal presence, identity, and the voluntariness of their act.
    What are the basic duties of a notary public? A notary public must ensure the signatory’s personal presence, verify their identity through competent evidence, and ascertain that the document is the signatory’s free act and deed. They must also maintain a notarial register and properly record all notarial acts.
    What happens if a notary public fails to fulfill these duties? Failure to fulfill these duties can result in administrative sanctions, including revocation of the notarial commission, disqualification from being a notary public, suspension from the practice of law, and potential criminal charges.
    What is the significance of notarization? Notarization converts a private document into a public document, making it admissible in court without further proof of authenticity, and lending it a degree of credibility and legal force.
    What evidence did the Court consider in this case? The Court considered the notarial certificate, which lacked details of the signatory’s identification, as well as the respondent’s failure to present the notarial register to support his claims. The court also weighed the credibility of the complainant’s testimony.
    What is the role of the Integrated Bar of the Philippines (IBP) in this case? The IBP investigated the complaint against Atty. Velasco and submitted a report and recommendation to the Supreme Court, which the Court largely adopted in its final decision.
    What is the Code of Professional Responsibility? The Code of Professional Responsibility is a set of ethical guidelines for lawyers in the Philippines, outlining their duties to the court, their clients, and the public.
    What specific violations of the Code of Professional Responsibility were found in this case? The Court found that Atty. Velasco violated Canon 1 (upholding the law) and Rule 1.01 (avoiding dishonest conduct) of the Code of Professional Responsibility.

    This case serves as a critical reminder of the responsibilities and duties of notaries public in the Philippines. Ensuring compliance with notarial rules protects the integrity of legal documents and the rights of individuals involved. Failure to adhere to these standards can result in severe penalties, impacting both the notary’s professional standing and the public’s trust in the legal system.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: IMELDA CATO GADDI vs. ATTY. LOPE M. VELASCO, A.C. No. 8637, September 15, 2014

  • Upholding Notarial Duty: Personal Appearance and Accountability in Document Attestation

    The Supreme Court held that a notary public who notarizes a document without the personal appearance of all affiants violates the Notarial Law and the Code of Professional Responsibility. Atty. Samuel SM. Lezama was found guilty of misconduct for notarizing a ‘Deed of Donation’ where one of the affiants, Jennifer Mahilum-Sorenson, was not physically present, as evidenced by immigration records. This decision underscores the importance of verifying the identity and presence of individuals signing documents and reinforces the responsibilities of notaries public in ensuring the integrity and authenticity of notarized documents, thereby safeguarding public trust and confidence in the notarial process.

    The Case of the Absent Affiant: Can a Notary Public Certify What Isn’t There?

    Emerita B. Mahilum filed an administrative complaint against Atty. Samuel SM. Lezama for notarizing a Deed of Donation involving her estranged husband, Rodolfo Mahilum, and their daughter, Jennifer Mahilum-Sorenson. The core issue was whether Atty. Lezama violated his duties as a notary public by attesting to the personal appearance of Jennifer when she was, in fact, abroad. The complainant presented evidence that Jennifer was in the United States on the date the document was notarized, challenging the validity and integrity of the notarization process.

    The case unfolded with the complainant, Emerita B. Mahilum, alleging that Atty. Lezama notarized the Deed of Donation on May 24, 2006, falsely attesting to the presence of both Rodolfo and Jennifer Mahilum-Sorenson. Atty. Lezama countered that all parties were present during the signing, asserting he knew Rodolfo personally and had no reason to doubt his representation that Jennifer had traveled from the USA. However, the Bureau of Immigration certification revealed that Jennifer did not enter the Philippines in 2006, undermining Atty. Lezama’s claim.

    The Integrated Bar of the Philippines (IBP) investigated the matter, finding that Atty. Lezama failed to exercise due diligence in verifying Jennifer’s identity. The IBP recommended the revocation of Atty. Lezama’s notarial commission and a two-year prohibition from being commissioned as a Notary Public. The IBP Board of Governors adopted this recommendation, leading Atty. Lezama to seek reconsideration, arguing that the complainant was not his client and that the notarization caused no damage.

    The Supreme Court, however, upheld the IBP’s findings, emphasizing the critical role of a notary public in ensuring the personal appearance of affiants. The Court cited Public Act No. 2103, also known as the Notarial Law, which explicitly requires the affiant to appear before the notary public, thus:

    Sec. 1. (a) The acknowledgement shall be before a notary public or an officer duly authorized by law of the country to take acknowledgements of instruments or documents in the place where the act is done. The notary public or the officer taking the acknowledgement shall certify that the person acknowledging the instrument or document is known to him and that he is the same person who executed it, acknowledged that the same is his free act and deed. The certificate shall be made under the official seal, if he is required by law to keep a seal, and if not, his certificate shall so state.

    Building on this statutory requirement, the Court also referenced Section 2(b) of Rule IV of the Rules on Notarial Practice of 2004, which mandates that a notary public must not perform a notarial act unless the affiant is physically present and personally known or identified through competent evidence.

    The Court underscored the significance of these rules by quoting Angeles v. Ibañez, stating:

    The physical presence of the affiants enables the notary public to verify the genuineness of the signatures of the acknowledging parties and to ascertain that the document is the parties’ free act and deed.

    Notarization of a private document converts such document into a public one, and renders it admissible in court without further proof of its authenticity. Courts, administrative agencies and the public at large must be able to rely upon the acknowledgment executed by a notary public and appended to a private instrument. Notarization is not an empty routine; to the contrary, it engages public interest in a substantial degree and the protection of that interest requires preventing those who are not qualified or authorized to act as notaries public from imposing upon the public and the courts and administrative offices generally.

    The Supreme Court differentiated between mere carelessness and deliberate disregard of the rules. Carelessness might imply forgetting to verify the identity of a present affiant, whereas Atty. Lezama knowingly attested to the presence of someone who was not there. The Court concluded that Atty. Lezama’s actions constituted a deliberate violation of the Notarial Law and the Code of Professional Responsibility.

    The implications of this misconduct are significant. A notarized document carries a presumption of due execution, and the notary’s signature and seal mislead the public into believing that all affiants personally appeared and attested to the truthfulness of the document’s contents. This misrepresentation can lead to precarious legal consequences should the document later be subject to judicial scrutiny. As the Court emphasized, a notary public must ensure that the persons signing the document are the same persons who executed it and personally appeared before him. This is crucial for verifying the genuineness of the signatures and ensuring the affiant’s free consent.

    The Court referenced Rule 1.01, Canon 1 of the Code of Professional Responsibility, which states, “A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.” Atty. Lezama’s actions were found to be in direct violation of this rule and the Notarial Law. Consequently, the Supreme Court found Atty. Samuel SM. Lezama guilty of violating the Notarial Law and the Code of Professional Responsibility. His incumbent notarial commission was revoked, and he was disqualified from being commissioned as a notary public for one year, effective immediately. The Court also issued a stern warning that any repetition of the same or similar offense would be dealt with more severely.

    FAQs

    What was the key issue in this case? The key issue was whether Atty. Lezama violated his duties as a notary public by attesting to the personal appearance of Jennifer Mahilum-Sorenson when she was not physically present during the notarization of a Deed of Donation. This raised questions about the integrity and validity of the notarization process.
    What evidence was presented to show Jennifer’s absence? The complainant presented a certification from the Bureau of Immigration showing that Jennifer Mahilum-Sorenson did not enter the Philippines in 2006, the year the Deed of Donation was notarized. This travel record contradicted Atty. Lezama’s claim that Jennifer was present.
    What did the IBP recommend? The IBP recommended the revocation of Atty. Lezama’s notarial commission and a two-year prohibition from being commissioned as a Notary Public. This recommendation was based on his failure to exercise due diligence in verifying Jennifer’s identity.
    What was the Supreme Court’s ruling? The Supreme Court found Atty. Lezama guilty of violating the Notarial Law and the Code of Professional Responsibility. His notarial commission was revoked, and he was disqualified from being commissioned as a notary public for one year.
    Why is the personal appearance of affiants important in notarization? The personal appearance of affiants allows the notary public to verify the genuineness of signatures and ensure the document is the free act and deed of the parties involved. This process transforms a private document into a public one, which can be relied upon in court.
    What specific laws did Atty. Lezama violate? Atty. Lezama violated Public Act No. 2103 (the Notarial Law), Section 2(b) of Rule IV of the Rules on Notarial Practice of 2004, and Rule 1.01, Canon 1 of the Code of Professional Responsibility. These laws and rules emphasize the necessity of personal appearance and prohibit deceitful conduct.
    What is the difference between carelessness and deliberate disregard in this context? Carelessness would imply that the affiant was actually present, but the notary public simply forgot to verify their identity. Deliberate disregard, as found in this case, means the affiant was not present, yet the notary public attested to their presence.
    What potential consequences arise from improper notarization? Improper notarization can mislead the public into believing that a document has been duly executed, potentially leading to legal complications and undermining the integrity of legal processes. It also erodes public trust in notarial acts.

    This case serves as a crucial reminder of the responsibilities and duties of notaries public in ensuring the integrity of legal documents. The ruling reinforces the need for strict adherence to the Notarial Law and the Code of Professional Responsibility. This decision underscores the importance of verifying the identity and presence of individuals signing documents, thereby safeguarding public trust and confidence in the notarial process.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: EMERITA B. MAHILUM VS. ATTY. SAMUEL SM. LEZAMA, A.C. No. 10450, July 30, 2014

  • Upholding Notarial Duty: Consequences of Improper Document Notarization

    In Pantoja-Mumar v. Flores, the Supreme Court emphasized the critical importance of proper notarization, particularly the requirement that a notary public must ensure the personal presence and identity of all signatories to a document. The Court suspended Atty. Januario C. Flores from the practice of law for one year, revoked his notarial commission, and disqualified him from reappointment for two years, due to his failure to properly authenticate a deed of extrajudicial partition and sale. This ruling reinforces the principle that notarization is not a mere formality, but a crucial act that imbues a private document with public trust and evidentiary weight.

    Signing on the Dotted Line: When is a Notarized Document Not Really Notarized?

    This administrative case arose from a complaint filed by Chita Pantoja-Mumar against Atty. Januario C. Flores. The core issue was the questionable notarization of an Extrajudicial Partition with Absolute Sale involving a three-hectare property. Chita alleged that Atty. Flores notarized the document despite her absence during the signing and also when one of the co-heirs, Maximina Pantoja, did not personally affix her thumbmark in his presence. The complainant argued that Atty. Flores’ actions constituted fraud, misrepresentation, deceit, falsification of document, and a breach of his oath as a lawyer.

    Atty. Flores defended his actions by claiming that he notarized the document in good faith, relying on the assurances of Mrs. Pantoja that her daughter, Maximina, would affix her thumbmark. He also pointed out that Chita Mumar was informed about the sale via registered mail, suggesting she had knowledge of the transaction. The Integrated Bar of the Philippines (IBP) investigated the matter, finding that Atty. Flores was indeed remiss in his duties as a notary public. The Investigating Commissioner cited respondent’s testimony in Civil Case No. DNA-574 and his own admission when she prepared her report.

    The Supreme Court, in its decision, underscored the significance of notarization as a process imbued with public interest. It highlighted that notarization transforms a private document into a public one, making it admissible in evidence without preliminary proof of authenticity. The Court emphasized that notaries public must exercise utmost care in complying with the elementary formalities of their duties.

    A notary public should not notarize a document unless the persons who signed the same are the very same persons who executed and personally appeared before him to attest to the contents and truth of what are stated therein.

    In this case, the Court found that Atty. Flores failed to ensure that all vendors-signatories were the very same persons who executed the deed and personally appeared before him. His actions undermined public confidence in notarial documents and constituted a breach of the Code of Professional Responsibility. This violation specifically implicated Canon 1, which requires lawyers to uphold the Constitution, obey the laws, and promote respect for legal processes, as well as Rule 1.01, which proscribes lawyers from engaging in unlawful, dishonest, immoral, or deceitful conduct.

    The Court acknowledged that disbarment is the most severe sanction, reserved for grave misconduct that affects a lawyer’s standing and moral character. Considering that this was Atty. Flores’ first administrative offense, the Court deemed a suspension from the practice of law for one year, along with the revocation of his notarial commission and disqualification from reappointment, as a more appropriate penalty.

    The decision emphasizes that while mistakes can occur, the duty to meticulously verify the identity of signatories is non-negotiable. A notary’s negligence impacts the reliability of legal documents and the integrity of the legal system. The message is clear: notarization demands diligence and a strict adherence to procedural requirements.

    FAQs

    What was the key issue in this case? The key issue was whether Atty. Januario C. Flores violated the Notarial Law and the Code of Professional Responsibility by improperly notarizing a deed of extrajudicial partition and sale. Specifically, the issue revolved around the absence of some signatories during the notarization process.
    What did Atty. Flores do wrong? Atty. Flores notarized a document without ensuring that all signatories were personally present and attested to the contents of the document before him. He also notarized the deed when one of the signatories, Maximina Pantoja, did not affix her thumbmark in his presence, and the complainant was absent during notarization.
    What is the significance of notarization? Notarization converts a private document into a public one, making it admissible in court without preliminary proof of authenticity. It imbues the document with a presumption of regularity and authenticity, thereby fostering public trust in legal instruments.
    What Canon of the Code of Professional Responsibility did Atty. Flores violate? Atty. Flores violated Canon 1 of the Code of Professional Responsibility, which requires lawyers to uphold the Constitution, obey the laws, and promote respect for legal processes, and Rule 1.01, which proscribes lawyers from engaging in unlawful, dishonest, immoral, or deceitful conduct.
    What was the penalty imposed on Atty. Flores? The Supreme Court suspended Atty. Flores from the practice of law for one year, revoked his notarial commission, and disqualified him from reappointment as a notary public for two years.
    Why wasn’t Atty. Flores disbarred? The Court considered that this was Atty. Flores’ first administrative offense. It opted for a less severe penalty than disbarment, finding that a suspension, revocation of his notarial commission, and disqualification from reappointment would suffice.
    What should notaries public do to avoid similar issues? Notaries public must ensure that all signatories are personally present before them, that they acknowledge their signatures voluntarily, and that they are the persons they claim to be. Thorough verification and adherence to notarial procedures are essential.
    What is the impact of this decision on the legal profession? This decision reinforces the importance of diligence and ethical conduct among lawyers, particularly those acting as notaries public. It highlights the responsibility of notaries to uphold the integrity of legal documents and the legal system.

    The Pantoja-Mumar v. Flores case serves as a reminder of the crucial role notaries public play in the legal system and underscores the importance of strict compliance with notarial laws. The decision reinforces the duty of lawyers to act with integrity, honesty, and diligence in all their professional endeavors, ultimately safeguarding public trust and confidence in the legal profession.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: CHITA PANTOJA-MUMAR v. ATTY. JANUARIO C. FLORES, A.C. NO. 5426, April 04, 2007

  • Notarial Duty: Lawyers Held Accountable for False Certifications in Legal Documents

    The Supreme Court’s decision underscores the critical responsibility of notaries public to ensure the authenticity of documents and the presence of all parties involved. This ruling highlights that lawyers acting as notaries must meticulously verify identities and the veracity of signatures, as neglecting these duties can lead to severe disciplinary actions. The decision emphasizes that notarization is not a mere formality but a process that imbues a private document with public trust, demanding utmost diligence from legal professionals.

    Falsified Signatures and a Negligent Notary: Can a Lawyer’s Oversight Undermine Legal Documents?

    In Cabanilla v. Cristal-Tenorio, Dominador Cabanilla filed a complaint against Atty. Ana Luz B. Cristal-Tenorio for notarizing a deed of sale where he alleged that he and some of his children did not appear before her, and their signatures were forged. The deed involved a portion of land he was selling to Rodolfo Sabangan. Cabanilla claimed that despite visible discrepancies in the document, Atty. Cristal-Tenorio proceeded with the notarization. The Integrated Bar of the Philippines (IBP) investigated the matter, finding that Atty. Cristal-Tenorio had indeed failed to properly verify the identities of the parties involved and recommended sanctions. This case puts into question the extent of a notary public’s responsibility in ensuring the validity of a legal document and the consequences of failing to uphold this duty.

    The Supreme Court affirmed the IBP’s findings, emphasizing that a **notary public** plays a crucial role in ensuring the integrity of legal documents. The court cited Section 1(a) of Act 2103, highlighting the requirement for a notary to certify that the person acknowledging the instrument is known to them and that they are the same person who executed it. This mandate ensures that the individual signing the document is indeed who they claim to be, preventing fraudulent activities. Furthermore, every document notarized must include the presentation of residence certificates to ascertain the identities of the persons appearing and to avoid impostors. Failure to comply with these requirements can lead to the revocation of a notary’s commission.

    In this instance, Atty. Cristal-Tenorio fell short of her duties in several respects. First, the deed of sale contained patent defects, indicating that Dominador Cabanilla only intended to sell a portion of the house, not the land. Despite this, the deed was notarized without any clarification or revision. The Supreme Court noted that a conscientious notary should have refrained from notarizing the deed and advised the parties to revise it. Second, the acknowledgment page included names of individuals who were not vendors in the deed, yet they were certified as such by Atty. Cristal-Tenorio. Finally, the acknowledgment lacked crucial details of the residence certificates of the parties involved, raising further doubts about the proper verification of their identities. These oversights led the Court to conclude that Atty. Cristal-Tenorio had notarized the document without the parties appearing before her, undermining the public’s confidence in notarial documents.

    The Court stressed that a notary public is duty-bound to exercise utmost care in performing their duties, as notarization converts a private document into a public one, making it admissible in court without further proof of authenticity. This decision highlights the importance of adhering to the **Code of Professional Responsibility**. Specifically, it was found that Atty. Cristal-Tenorio breached Canon I, which requires lawyers to uphold the Constitution, obey the laws, and promote respect for the law. Furthermore, she violated Rule 1.01, which prohibits lawyers from engaging in unlawful, dishonest, immoral, or deceitful conduct. Finally, the Court stated that by falsely stating that the parties personally appeared before her, Atty. Cristal-Tenorio violated Rule 10.01 of the Code of Professional Responsibility, which requires lawyers to do no falsehood. This case underscores the ethical responsibilities of lawyers as notaries public, emphasizing the need for truthfulness and integrity in their professional conduct.

    The Supreme Court underscored that a notary public must not notarize documents without ensuring the presence and proper identification of the signatories. It emphasizes the need for lawyers to act with utmost care and diligence when performing notarial functions. This decision reinforces the ethical responsibilities of lawyers to uphold the law and promote respect for legal processes. Consequently, the Court revoked Atty. Cristal-Tenorio’s commission as Notary Public, disqualified her from being commissioned as such for two years, and suspended her from the practice of law for one year.

    FAQs

    What was the key issue in this case? The key issue was whether Atty. Ana Luz B. Cristal-Tenorio, as a notary public, properly notarized a deed of sale, given allegations that some parties did not appear before her and that the document contained discrepancies. The Court had to determine if she fulfilled her duty to ensure the authenticity and validity of the notarized document.
    What is the role of a notary public? A notary public is authorized to administer oaths and affirmations, take affidavits and depositions, and perform other acts, including notarizing documents. Notarization converts a private document into a public one, making it admissible in court without further proof of authenticity.
    What duties does a notary public have when notarizing a document? A notary public must certify that the person acknowledging the instrument is known to them and is the same person who executed it, ensuring the individual signing is who they claim to be. The notary must also ensure that the parties have presented their residence certificates and must include the details in the document.
    What happens if a notary public fails to fulfill their duties? If a notary public fails to fulfill their duties, such as failing to verify the identity of the parties or notarizing a document with patent defects, their commission may be revoked. They may also face disqualification from being commissioned as a notary public and suspension from the practice of law.
    What violations did Atty. Cristal-Tenorio commit? Atty. Cristal-Tenorio notarized a deed of sale with patent defects, included individuals as vendors who were not parties to the deed, and failed to properly verify the identities of the parties involved. She also made an untruthful statement under oath regarding the acknowledgment.
    What is the Code of Professional Responsibility? The Code of Professional Responsibility outlines the ethical standards expected of lawyers in the Philippines. It includes canons and rules governing their conduct, including upholding the Constitution, obeying the laws, and avoiding dishonest conduct.
    What penalties did Atty. Cristal-Tenorio face? As a result of her actions, Atty. Cristal-Tenorio’s commission as Notary Public was revoked, she was disqualified from being commissioned as such for two years, and she was suspended from the practice of law for one year.
    Why is notarization important? Notarization is essential because it adds a layer of authenticity and validity to legal documents. It helps prevent fraud, ensures that documents are properly executed, and makes them more reliable in legal proceedings.
    How does this case affect the legal profession? This case serves as a reminder to lawyers acting as notaries public to take their responsibilities seriously and to ensure they follow all required procedures. It highlights that failing to do so can lead to severe disciplinary actions and can undermine public confidence in the legal profession.

    This case highlights the crucial role that lawyers play in upholding the integrity of legal documents. The Supreme Court’s decision serves as a stern reminder of the responsibilities and ethical obligations that come with being a notary public. By holding Atty. Ana Luz B. Cristal-Tenorio accountable for her actions, the Court reaffirmed the importance of truthfulness, diligence, and adherence to the law in the practice of law.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Cabanilla v. Cristal-Tenorio, A.C. No. 6139, November 11, 2003

  • Can a Notary Public Also Be a Witness? Understanding Document Notarization in the Philippines

    Clarifying the Roles: When a Philippine Notary Public Can Also Act as a Witness

    TLDR: In the Philippines, a notary public is generally allowed to also act as a witness to a document they are notarizing, except in specific cases like wills. This Supreme Court case clarifies this point, dismissing a complaint based on the misconception that these roles are mutually exclusive. It underscores the importance of understanding the nuances of notarization and the limited grounds for challenging notarized documents.

    A.C. No. 4751, July 31, 2000

    INTRODUCTION

    Imagine you’re finalizing a crucial property sale, ensuring every legal box is ticked. You hire a notary public to authenticate the documents, but a question arises: can this notary public also serve as a witness to the signing? This scenario isn’t just hypothetical; it reflects a common misunderstanding about the roles of notaries and witnesses in Philippine law. The case of Solarte v. Pugeda addresses this very issue, providing clarity on when a notary public can indeed wear both hats. This case is a vital reminder that assumptions about legal processes can lead to unnecessary disputes and highlights the importance of sound legal advice when dealing with notarized documents.

    Emelita Solarte filed an administrative complaint against Atty. Teofilo F. Pugeda, a former municipal judge and notary public ex officio. Solarte alleged gross misconduct, claiming Pugeda improperly notarized deeds of sale in the 1960s where he also acted as a witness. She argued this was legally irregular and indicative of fraudulent activity related to land she claimed ancestral ties to. The core legal question was whether a notary public in the Philippines is prohibited from also being a witness to the document they notarize.

    LEGAL CONTEXT: NOTARIZATION AND WITNESSING IN THE PHILIPPINES

    In the Philippines, notarization is a crucial process that adds a layer of authenticity and legal weight to private documents. A notary public, authorized by the court, acts as an impartial witness to the signing of a document, deterring fraud and ensuring due execution. Their role is to attest that the signatures on the document are genuine and that the signatories appeared before them and acknowledged the document as their free act and deed.

    Witnessing, on the other hand, serves to corroborate the signing of a document. Witnesses are present at the signing to attest to the act of signing itself and the identity of the signatories. While notarization focuses on the authenticity of signatures and acknowledgment, witnessing provides additional verification of the signing event.

    The authority for municipal judges to act as notaries public ex officio during the time of the questioned notarizations stemmed from the Judiciary Act of 1948 and the Revised Administrative Code. However, the Supreme Court, in the 1980 case of Borre v. Moya, clarified that this ex officio power was limited to documents connected with the exercise of their official functions. Crucially, the legal framework at the time, and even currently, does not explicitly prohibit a notary public from also acting as a witness, except in specific instances such as wills, which have stricter requirements under the Civil Code of the Philippines regarding witnesses.

    Relevant to this case is the absence of a direct legal prohibition against a notary public also being a witness. As the Supreme Court has stated in prior cases, such as Mahilum v. Court of Appeals, and as reiterated in Solarte v. Pugeda, Philippine law generally permits this dual role, reinforcing the principle of freedom in private transactions unless explicitly restricted by law.

    CASE BREAKDOWN: SOLARTE VS. PUGEDA

    Emelita Solarte, claiming to be a descendant of the original land owner, Catalino Nocon, suspected fraud in deeds of sale notarized by Atty. Teofilo Pugeda decades prior, in the 1960s. Solarte’s grandfather was one of Catalino’s children, and she believed the land partition and subsequent sales were wrongful. Her suspicion arose in the 1990s when she sought to title her father’s portion of the property.

    Unable to get copies of the deeds from Atty. Pugeda, she obtained access through another Nocon descendant, Herminia. Solarte reviewed and recorded the documents, noting that Atty. Pugeda had acted as both notary public and witness. She also pointed out the absence of the vendee’s signature on one deed and alleged that Atty. Pugeda and his wife were improperly administering the property.

    Solarte filed a complaint for gross misconduct against Atty. Pugeda, arguing that a notary public could not legally act as a witness. She claimed this, along with other perceived irregularities, indicated fraudulent partition and sale of Catalino Nocon’s property. She asserted she only recently discovered this fraud when pursuing her father’s land title.

    Atty. Pugeda defended himself by stating:

    1. He was not obligated to provide documents as he was no longer a notary public ex officio. He was willing to search for the old documents but Solarte left for the USA prematurely.
    2. No law prohibits a notary public from also being a witness.
    3. As a municipal judge in the 1960s, he had the authority to notarize documents under existing laws at the time, before the Borre v. Moya clarification.
    4. He denied any involvement in the property partition or administration.

    Atty. Pugeda also presented court decisions from prior cases (Civil Case No. TM-273 and CA-G.R. No. 49757-R) that had already upheld the validity of the partition and deeds of sale.

    The Supreme Court highlighted key points in its reasoning:

    • No Legal Prohibition: The Court firmly stated, “Nothing in the law prohibits a notary public from acting at the same time as witness in the document he notarized.” The exception, as noted, is for wills.
    • Lack of Evidence of Fraud: Solarte’s allegations of fraud and involvement of Atty. Pugeda in the partition were unsubstantiated. The Court stressed that “Such a grave charge…needs concrete substantiation to gain credence. It could not prosper without adequate proof.”
    • Prior Litigation and Finality: The Court pointed out that the validity of the partition and sales had already been litigated and upheld in previous court cases dating back to 1979. These decisions had become final, and Solarte could not re-litigate these issues through an administrative complaint. The Court noted Solarte’s attempt to mislead them by claiming recent discovery of fraud, when records showed her family had challenged the partition decades earlier.

    Ultimately, the Supreme Court agreed with the Integrated Bar of the Philippines (IBP) recommendation to dismiss the complaint, finding it utterly without merit. The Court’s decision rested on the lack of legal basis for Solarte’s claim and the res judicata effect of prior court decisions.

    As the Supreme Court concluded, “This administrative charge against respondent lawyer, who as municipal judge notarized the documents involved, is utterly without merit.”

    PRACTICAL IMPLICATIONS: WHAT THIS MEANS FOR NOTARIZATION

    Solarte v. Pugeda serves as a clear affirmation that in the Philippines, the roles of notary public and witness are not mutually exclusive for most documents. This ruling has significant practical implications for legal practice and everyday transactions:

    • Streamlined Document Signing: It simplifies the notarization process, as parties do not necessarily need to find separate individuals to act as notary and witnesses, except when dealing with wills. This is particularly helpful in remote areas or urgent situations.
    • Reduced Risk of Technical Challenges: The case reduces the likelihood of legal challenges to notarized documents based solely on the notary public also acting as a witness. This promotes the stability and reliability of notarized documents in legal and commercial transactions.
    • Focus on Substantive Issues: By clarifying this procedural aspect, the ruling encourages focus on more substantive issues in legal disputes, such as actual fraud or coercion, rather than technicalities of notarization unless those technicalities violate explicit legal requirements (like witness requirements for wills).

    Key Lessons:

    • Know the Law: Assumptions about legal procedures can be costly. Always verify legal requirements, especially concerning notarization and witnessing, with reliable legal sources or professionals.
    • Substantiate Claims: Grave accusations, such as fraud against legal professionals, require solid evidence, not just suspicion.
    • Respect Final Judgments: Court decisions, once final, are binding and cannot be circumvented through administrative complaints on the same issues.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q: Can my lawyer act as a notary public for my documents?

    A: Yes, lawyers in the Philippines who are in good standing with the Integrated Bar of the Philippines (IBP) can apply to become notaries public. If your lawyer is a notary public, they can notarize your documents.

    Q: Are there any documents where the notary public cannot be a witness?

    A: Yes. Wills require specific types and numbers of witnesses who must be distinct from the notary public. This is to ensure the will’s validity and prevent undue influence.

    Q: What makes a document validly notarized in the Philippines?

    A: A validly notarized document generally requires the signatory to personally appear before the notary public, present valid identification, and acknowledge that they signed the document freely and voluntarily. The notary public then affixes their signature and seal, recording the notarization in their notarial register.

    Q: What should I do if I suspect fraud in a notarized document?

    A: If you suspect fraud, gather any evidence you have and consult with a lawyer immediately. They can advise you on the best course of action, which may include legal proceedings to challenge the document’s validity.

    Q: Is it always necessary to notarize a document to make it legally binding in the Philippines?

    A: Not all documents require notarization to be legally binding. However, notarization adds a strong presumption of regularity and authenticity, making the document more readily admissible in court and generally more legally robust, especially for important transactions like real estate deals, contracts, and affidavits.

    ASG Law specializes in Real Estate Law and Litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.