This case has been cited 2 times or more.
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2015-06-16 |
PEREZ, J. |
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| Came the anniversary, officers and members sported t-shirts with inscriptions "CNA Incentive Ihatag Na, Dir. Braganza Pahawa Na!" at the beginning of the Fun Run at Victoria Plaza at around 6:30 in the morning and continued to wear the same inside the premises of the DCWD office during the office hours. Also, one of the members of the Board of Directors of NAMADACWAD Gregorio S. Cagula (Cagula), with the help of some of its members, attached similar inscriptions and posters of employees' grievances to a post in the motor pool area, an area not among the officially designated places[5] for posting of grievances as prescribed by DCWD's Office Memorandum[6] dated 8 February 1996 and pursuant to CSC Memorandum Circular No. 33,[7] Series of 1994 (MC No. 33).[8] | |||||
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2014-01-15 |
PERLAS-BERNABE, J. |
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| The defective notarization of the subject SPA also means that the said document should be treated as a private document and thus examined under the parameters of Section 20, Rule 132 of the Rules of Court which provides that "[b]efore any private document offered as authentic is received in evidence, its due execution and authenticity must be proved either: (a) by anyone who saw the document executed or written; or (b) by evidence of the genuineness of the signature or handwriting of the maker x x x." Settled is the rule that a defective notarization will strip the document of its public character and reduce it to a private instrument, and the evidentiary standard of its validity shall be based on preponderance of evidence.[40] | |||||