A.C. No. 9514 - Jandoquile vs. Revilla, Jr.

Complainant: Bernard N. Jandoquile filed a complaint for disbarment.
Respondent: Atty. Quirino P. Revilla, Jr., who is accused of violating the 2004 Rules on Notarial Practice.
The case involves a notarial act performed by the respondent which is alleged to have been tainted by his personal relationships.

Atty. Revilla, Jr. notarized a complaint-affidavit signed by the following three individuals:

Heneraline Brosas is the sister of Heizel Wynda Brosas Revilla, who is the wife of Atty. Revilla, Jr.
Herizalyn Brosas Pedrosa is related as sister-in-law via the same familial connection.
Elmer Alvarado is the live-in houseboy of the Brosas family.

Complaint alleges that Atty. Revilla, Jr. notarized the complaint-affidavit in violation of Section 3(c), Rule IV of the 2004 Rules on Notarial Practice.

This provision disqualifies a notary public from notarizing a document if the principal is related by affinity within the fourth civil degree.

Additionally, it is alleged that he failed to require the affiants to present valid identification cards during the notarization.

Atty. Revilla, Jr. acknowledged notarizing the complaint-affidavit and thus did not deny the material allegations regarding his familial connection.
He argued that his role in notarizing the document was akin to acting as counsel to the affiants rather than solely as a notary public.
He maintained that his personal knowledge of the affiants justified his decision not to require the presentation of valid identification cards.
The defense emphasizes that the exception provided under the ajurata or single act rule [Section 6, Rule II] supports his reliance on personal acquaintance.

The facts of the case are undisputed by both parties.
The Court found it more expedient to resolve the case directly rather than refer it for investigation by the Integrated Bar of the Philippines.
The emphasis was on determining whether the violation, despite its clarity, warranted the ultimate remedy of disbarment.

Is the act of notarizing a document involving relatives within the fourth civil degree of affinity a sufficient ground for disbarment under Section 3(c), Rule IV of the 2004 Rules on Notarial Practice?
Does the disqualification rule apply strictly regardless of the respondent’s status in the document notarization process?

Can Atty. Revilla, Jr. be held liable for not requiring the affiants to show their valid identification cards?
Does his defense relying on personal acquaintance with the affiants provide a sufficient legal basis to justify not verifying their identities?

Given that the respondent admitted to notarizing the document notwithstanding his disqualification, should the penalty be disbarment or a less severe sanction?
Is the misconduct associated solely with the act of notarization, or do additional aggravating factors (such as deceit or malpractice) warrant a harsher punishment?