A.C. No. 12084 - HERNANIE P. DANDOY, COMPLAINANT, V. ATTY. ROLAND G. EDAYAN.

Ruling

accordingly, recommended that respondent's notarial commission, if existing, be revoked and that he be disqualified from being commissioned as a notary public for a period of two (2) years. [15] The IBP-IC found that respondent failed to confirm the identity of the person claiming to be Jacinto through the competent evidence of identity required by the 2004 Notarial Rules the controlling rules on notarial practice at the time of the notarization of the SPA and the Deed, not the Notarial Law invoked by respondent. In this regard, the IBP-IC pointed out that under the 2004 Notarial Rules, competent evidence of identity includes: (a) a government-issued identification document bearing their respective photographs, which clearly does not include the community tax certificate presented in this case; and (b) affirmation of one credible witness not privy to the instrument, etc. who is personally known to the notary public and who personally knows the individual, which, in this case, was not satisfied by the statements made by Felipe or Garzo as to the identity of Jacinto because they are privy to the Deed and the SPA. Finally, the IBP-IC noted the apparent discrepancy between the signatures affixed by the person claiming to be Jacinto in the SPA and in the Deed which, to the IBP-IC, should have already raised suspicion on respondent's part and prompted him to require a signature and photograph-bearing identification card from said person. Being a notary public, and therefore an officer of the court, the IBP-IC pointed out that respondent must strictly comply with the rules on notarial practice as may be issued by the Court. [16] The IBP-IC, however, found the evidence insufficient to show that respondent wilfully and maliciously conspired with Garzo and Felipe in depriving Dandoy and his siblings of their grandmother's property in order to hold him administratively liable under the CPR. [17] In a Resolution [18] dated February 25, 2016, the IBP Board of Governors adopted the above report and recommendation of the IBP-IC. Dissatisfied, respondent sought reconsideration, [19] which the IBP denied in a Resolution [20] dated April 20, 2017. The Issue Before the Court The issue for the Court's resolution is whether or not the IBP correctly found respondent liable for violation of the 2004 Notarial Rules. The Court's Ruling The Court affirms the findings and adopts the recommendations of the IBP with modifications. Time and again, the Court has emphasized that the act of notarization is impressed with public interest. Notarization converts a private document to a public document, making it admissible in evidence without further proof of its authenticity. [21] A notarial document is, by law, entitled to full faith and credence. [22] As such, a notary public must observe with utmost care the basic requirements in the performance of his duties in order to preserve the confidence of the public in the integrity of the notarial system. [23] In this light, the Court