Lawyer suspended for notarizing document while signatory was abroad

MANILA, Philippines — The Supreme Court on Monday, September 16 said it suspended a lawyer after he forged his client’s signature and notarized a special power or attorney despite his client being out of the country.

This resulted in the lawyer, Lorenzo Reago, being suspended from the practice of law for two years and also prohibited from being commissioned as a notary public for two years.

He is also directed by the high court to file a manifestation before the Supreme Court to indicate that his suspension has started.

Complainant Maria Brozas-Garri accused Reago of failing to return her copy of the Transfer Certificate of Title which he borrowed, despite repeated requests. 

She also claimed that lawyer Reago prepared a Special Power of Attorney (SPA) allowing his wife to lease out her house and lot and he notarized the document even though her signature was forged, as she was out of the country at the time.

Additionally, the complainant accused Reago of neglecting to file important legal paperwork and failing to provide updates in a case where he was representing her and other plaintiffs.

In his defense, Reago asserted that he already returned the Transfer Certificate Title to Brozas-Garri through her sister in 2016, with proof of receipt. 

Reago claimed the Special Power of Attorney was created with her full knowledge and that she agreed to the lease and even received rental payments. 

The case was referred to the Integrated Bar of the Philippines (IBP) for further investigation and recommendations.

The IBP then recommended that Reago should be administratively liable for violating Canon 1 of the old Code of Professional Responsibility (CPR) and the 2004 Rules on Notarial Practice.

The IBP Board further noted that Reago aggravated his violation by knowingly preparing and notarizing a document with a forged signature while Brozas-Garri was abroad.

Reago then filed a motion for reconsideration but was denied. This prompted him to appeal his case before the Supreme Court.

The Supreme Court has upheld the findings of the IBP. In its ruling, it stressed that notarization is not a mere formality but an act of significant public interest, converting private