Evidentiary weight of notarized documents
A notarized document carries the evidentiary weight conferred upon it with
respect to its due execution, and it has in its favor the presumption of
regularity which may only be rebutted by evidence so clear, strong and
convincing as to exclude all controversy as to the falsity of the
certificate.[1] The Supreme Court has held:
Deeply embedded in our jurisprudence is the rule that notarial documents celebrated with all the legal requisites under the safeguard of a notarial certificate is evidence of a high character and to overcome its recitals, it is incumbent upon the party challenging it to prove his claim with clear, convincing and more than merely preponderant evidence.
x x x The burden of proof to overcome the presumption of due execution of a notarial document lies on the one contesting the same. Furthermore, an allegation of forgery must be proved by clear and convincing evidence, and whoever alleges it has the burden of proving the same.[2]
[1] Pan Pacific Industrial Sales Co., Inc. v. Court of Appeals, G.R. No. 125283, February 10, 2006, 482 SCRA 164, 174.
[2] Id. at 174-175.