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JUAN DELA RAMA v. OSCAR PAPA

This case has been cited 3 times or more.

2011-10-19
PERALTA, J.
evidentiary weight conferred upon them with respect to their due execution[27] and enjoy the presumption of regularity which may only be rebutted by evidence so clear, strong and convincing as to exclude all controversy as to falsity.[28] The presumptions that attach to notarized documents can be affirmed only so long as it is beyond dispute that the notarization was regular.[29] A defective notarization will strip the document of its public character and reduce it to a private instrument.[30]  Consequently, when there is a defect in the notarization of a document, the clear and convincing evidentiary standard normally attached to a duly-notarized document is dispensed with, and the measure to test the validity of such document is preponderance of evidence.[31]
2010-04-15
PERALTA, J.
Moreover, not all notarized documents are exempted from the rule on authentication.[20] Thus, an affidavit does not automatically become a public document just because it contains a notarial jurat.[21] The presumptions that attach to notarized documents can be affirmed only so long as it is beyond dispute that the notarization was regular.[22]