Cited Laws
Accordingly, it cannot be extended to the acts complained of in this case. The alleged "warrantless search" made by Roque, a co-employee of appellant at the treasurer's office, can hardly fall within the ambit of the constitutional proscription on unwarranted searches and seizures. Consequently, in this case where complainants, as private individuals, obtained the subject birth records as evidence against respondent, the protection against unreasonable searches and seizures does not apply. Since both Rule 24, Administrative Order No. 1, series of 1993 and the Revised Rules on Evidence do not provide for the exclusion from evidence of the birth certificates in question, said public documents are, therefore, admissible and should be properly taken into consideration in the resolution of this administrative case against respondent. [18] Similarly, the 2004 Rules on Notarial Law contain no provision declaring the inadmissibility of documents obtained in violation thereof. Thus, the IBP correctly considered in evidence the other notarized documents submitted by complainant as additional evidence. Respondents argument that the Urgent Ex-Parte Motion of complainant constitutes a supplemental pleading must fail as well. As its very name denotes, a supplemental pleading only serves to bolster or adds something to the primary pleading. Its usual office is to set up new facts which justify, enlarge or change the kind of relief with respect to the same subject matter as the controversy referred to in the original complaint. [19] Accordingly, it cannot be said that the Urgent Ex-Parte Motion filed by complainant was a supplemental pleading. One of her charges against respondent is that the latter notarized incomplete documents, as shown by the SPAs and lease agreement attached to the Affidavit-Complaint. Complainant is not legally barred from submitting additional evidence to strengthen the basis of her complaint. Going now into the substance of the charges against respondent, the Court finds that she committed misconduct and grievously violated her oath as a notary public. The important role a notary public performs cannot be overemphasized. The Court has repeatedly stressed that notarization is not an empty, meaningless routinary act, but one invested with substantive public interest. Notarization converts a private document into a public document, making it admissible in evidence without further proof of its authenticity. Thus, a notarized document is, by law, entitled to full faith and credit upon its face. It is for this reason that a notary public must observe with utmost care the basic requirements in the performance of his notarial duties; otherwise, the public's confidence in the integrity of a notarized document would be undermined. [20] Where the notary public admittedly has personal knowledge of a false statement or information contained in the instrument to be notarized, yet proceeds to affix the notarial seal on it, the Court must not hesitate