G.R. No. 165835 - Garcia vs. Sandiganbayan

Complainants Spouses Andre and Maria Fatima Chambon were creditors of Suzette Camasura Auman (also known as Mrs. Suzette Camasura Remoreras).
Remoreras executed a real estate mortgage over a parcel of land (TCT No. 29490), annotated in the Registry of Deeds of Mandaue City in 2006, which was handed to Spouses Chambon.

Upon Remoreras’s default, Spouses Chambon initiated extrajudicial foreclosure with a public auction scheduled on April 27, 2010.
They learned of an RTC Order dated March 24, 2008 directing issuance of a new duplicate TCT based on an alleged Notice/Affidavit of Loss filed by Remoreras.

Prior to the auction, Remoreras filed a complaint to enjoin the sale, presenting a purported Release of Mortgage allegedly executed by Spouses Chambon.
Spouses Chambon discovered that both the Notice/Affidavit of Loss and the Release of Mortgage were notarized by Atty. Christopher S. Ruiz with defects:

The jurat on the Notice lacked any competent proof of identity.
The Release was denied by the Chambons and bore incomplete entries in Ruiz’s Notarial Register.

Spouses Chambon filed a complaint for gross violations of Section 2(b)(2), Rule IV and Section 2(a), (d), (e), Rule VI of the 2004 Rules on Notarial Practice.
In his Answer, Respondent denied notarizing the Release and blamed his secretary for lapses in the Notarial Register entries of the Notice.
The IBP-Committee on Bar Discipline (CBD) recommended revocation of Ruiz’s commission and a four-year bar from reappointment.
The IBP Board adopted the findings but modified the penalty to immediate revocation, three-year disqualification as notary, and three-year suspension from law practice.

Whether Atty. Christopher S. Ruiz should be administratively disciplined for gross violations of the 2004 Rules on Notarial Practice based on the complaint and evidence.