UY V. SANO (DISBARMENT)

This is a disbarment case filed by complainant Uy against respondent Sano for allegedly notarizing several documents despite the expiration of his commission.

It is worth stressing that the practice of law is not a right but a privilege bestowed by the State on those who show that they possess, and continue to possess the qualifications required by law for the conferment of such privilege. Membership in the bar is a privilege with conditions.

It has been emphatically stressed that notarization is not an empty, meaningless, routinary act. It is invested with substantive public interest, such that only those whoa re qualified and authorized may act as notaries public. It must be underscored that the act of notarization by a notary public converts a private document into a public document making it admissible in evidence without further proof of authenticity. A notarial document is, by law, entitled to full faith and credit upon its face. For this reason, notaries public must observe with utmost case the basic requirements in the performance of their duties.

To be sure, the requirements for the issuance of a commission as notary public must not be treated as a mere casual formality. The Court has characterized a lawyer's act of notarizing documents without the requisite commission therefor as reprehensible, constituting as it does, not only malpractice, but also the crime of falsification of public documents. For such reprehensible conduct, the Court has sanctioned erring lawyers by suspension from the practice of law, revocation of the notarial commission, and disqualification from acting as such, and even disbarment.