• This administrative case involves a lawyer, Atty. Glenn Eric Peralta, who admitted to notarizing a Partition Agreement purportedly signed by two brothers who had been deceased for years. The Supreme Court found him guilty of violating the Rules on Notarial Practice and the Code of Professional Responsibility. Despite the fact that Atty. Peralta had already been disbarred in a previous, unrelated case, the Court still imposed penalties of suspension, revocation of notarial commission, and a fine, to be recorded in his file and considered in any future petition to lift his disbarment.

• The Complainant: Loreta Hedocil-Menioria is the sister of Melecio and Artemio Hedocil.
• The Deceased Signatories: Her brothers, Melecio and Artemio, died on April 17, 1984, and November 22, 2005, respectively.
• The Falsified Document: On November 17, 2017, years after both brothers had passed away, Atty. Peralta notarized a Partition Agreement supposedly signed by them.
• Respondent's Admission: Atty. Peralta admitted that he prepared, signed, and had the document notarized without the signatories being present, claiming he was pressed for time and trusted the wives of the deceased who were his regular clients.

• IBP Recommendation: The Integrated Bar of the Philippines (IBP) found Atty. Peralta guilty of violating the Rules on Notarial Practice and the Code of Professional Responsibility (CPR). It recommended a two-year suspension from the practice of law, revocation of his notarial commission, and perpetual disqualification from being a notary public.
• Supreme Court Review: The case was elevated to the Supreme Court for final action.

• Did Atty. Peralta violate his duties as a notary public and his lawyer's oath by notarizing a document without the personal appearance of the signatories, who were already deceased?
• What is the appropriate penalty for such a violation, especially when the respondent has already been disbarred in a separate case?

The Supreme Court found Atty. Peralta GUILTY of violating the Rules on Notarial Practice and the CPR.

• Violation Established: The Court held that by notarizing the document without the personal appearance of the signatories (who were deceased), Atty. Peralta clearly violated the explicit requirements of the Rules on Notarial Practice. This act also constituted a violation of his lawyer's oath and the CPR's prohibition against engaging in unlawful, dishonest, or deceitful conduct.
• Effect of Prior Disbarment: The Court noted that Atty. Peralta had already been disbarred in 2022. While a penalty of suspension can no longer be imposed, the Court still imposed it for the purpose of recording it in his personal file, to be considered in any future petition to lift his disbarment.
• Final Penalty: The Court imposed a one-year suspension (for recording purposes), revoked his notarial commission, disqualified him from being a notary public for two years, and ordered him to pay a fine of PHP 40,000.00.

• Personal Appearance is Mandatory: A notary public must not notarize a document unless the signatories are personally present at the time of notarization and are identified through competent evidence of identity.
• Notarization is a Public Function: Notarization is not a meaningless act; it converts a private document into a public one, entitled to full faith and credit. A violation undermines public trust.
• Quantum of Proof in Disbarment Cases: The required evidentiary standard in administrative cases against lawyers is substantial evidence, not preponderance of evidence or proof beyond reasonable doubt.
• Penalty on a Disbarred Lawyer: While a disbarred lawyer cannot be further suspended, the Court can still impose a penalty (like suspension or a fine) to be recorded in their file, which will be considered in any future petition for reinstatement.