A.C. No. 12877 - IN RE: Mara

The administrative case originated from the first indorsement dated March 11, 2014, filed by Graft Investigation and Prosecution Officer II Anna Francesca M. Limbo of the Office of the Ombudsman.
It stemmed from a referral of the Resolution in OMB-C-C-13-0104 to the Integrated Bar of the Philippines (IBP) to determine whether Atty. Socrates G. Maranan had committed a violation of the 2004 Rules on Notarial Practice and/or the Code of Professional Responsibility.

Atty. Maranan was implicated following a criminal complaint initiated by then Vice Mayor Francisco “Isko Moreno” Domagoso.
Domagoso was charged with falsification of public documents and violation of Section 3(e) of Republic Act No. 3019, alleging that consultancy contracts—executed in the name of the Manila City Government—were signed with individuals who were either deceased or abroad.
Domagoso contended that he had signed those contracts based on the assurance of his former Secretary, Abraham Cabochan, while pointing to Atty. Maranan as the one who notarized the disputed contracts.

Atty. Maranan denied authoring or notarizing the consultancy contracts.
He claimed that the signatures appearing on these contracts were vastly different from his specimen signatures on file with the Notarial Section of the Regional Trial Court (RTC) of Manila.
Additionally, he argued that the consultancy contracts were not included in his monthly notarial reports submitted to the RTC.

The Investigating Commissioner initially recommended the dismissal of the administrative case against Atty. Maranan, citing lack of clear and convincing evidence.
However, the IBP Board of Governors reversed the commissioner’s recommendation by finding substantial evidence that Atty. Maranan violated the 2004 Notarial Rules.

The Board emphasized that, despite the alleged discrepancies in the signatures, the presence of his notarial seal on the contracts could not be dissociated from his accountability.
The failure to exercise proper safeguards regarding his notarial seal was deemed a significant breach.

Atty. Maranan was found to have the duty to secure and safeguard his notarial seal, a duty explicitly mandated by the 2004 Notarial Rules.
The Board recommended the following penalties:

Atty. Maranan moved for reconsideration of the said decision.
His motion for reconsideration was denied via a resolution dated June 18, 2019, thus affirming the disciplinary measures imposed.

Whether or not there exist sufficient grounds to hold Atty. Socrates G. Maranan administratively liable for his alleged failure to safeguard his notarial seal.

Whether Atty. Maranan’s negligence in preventing the unauthorized use of his notarial seal constitutes a violation of the 2004 Rules on Notarial Practice.
Whether his claim that the signatures on the consultancy contracts were forged can absolve him from the responsibilities inherent in notarization.