Supreme Court: Forged Documents Remain Void, Even if Notarized
- Yasser Aureada
- 5 days ago
- 2 min read
The Supreme Court of the Philippines has made it clear: a forged document is void, even if notarized.
In the case of Chua v. Bank of Commerce (G.R. No. 263632), the Supreme Court ruled that the presumption of authenticity attached to notarized documents can be overturned when there is sufficient evidence of forgery or fraud.
Background of the Case
Gil Chua was sued by the Bank of Commerce as one of the alleged sureties for a ₱150 million loan extended to Interbrand Logistics and Distribution, Inc. The bank presented a notarized Continuing Surety Agreement (CSA) bearing Chua’s signature.
However, Chua denied ever signing the CSA or appearing before a notary public. He emphasized that he held no position or interest in Interbrand, unlike the other signatories.
Despite the notarization, the Supreme Court sided with Chua, noting several irregularities:
The bank had no specimen signature to verify the CSA.
The supposed notary public was never presented in court.
The CSA had identical witnesses as another agreement allegedly signed in a faraway location on the same day, raising serious doubts about its authenticity.
Supreme Court’s Key Ruling
The Court reiterated that while notarized documents enjoy a presumption of regularity, this presumption is not absolute. If a party can prove that a notarized document is forged or fabricated, it becomes legally void and unenforceable.
“Notarization does not cure a forged document.” — Associate Justice Amy C. Lazaro-Javier
What This Means for You
This ruling is a strong reminder to verify the authenticity of any document before relying on it — even if it's notarized. In legal disputes, proof always outweighs presumption.
If you’ve been asked to sign documents, or if you suspect that a document with your name was signed or notarized without your knowledge, seek legal help immediately.
Need legal guidance on contracts or document authentication? Contact us today and let our legal team help you navigate your options.
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