G.R. No.

200383

NORMA M. DIAMPOC, Petitioner

vs.
JESSIE BUENAVENTURA and THE REGISTRY OF DEEDS FOH THE CITY OF TAGUIG,
Respondents

It must be remembered, however, that "the absence of notarization of the deed of sale would not
invalidate the transaction evidenced therein"; it merely "reduces the evidentiary value of a document
to that of a private document, which requires proof of its due execution and authenticity to be
admissible as evidence."13 "A defective notarization will strip the document of its public character and
reduce it to a private instrument. 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."

G.R. No. 194189, September 14, 2017

RAFAEL ALMEDA, EMERLINA ALMEDA-LIRIO, ALODIA ALMEDA-TAN, LETICIA ALMEDA-MAGNO,

NORMA ALMEDA-MATIAS AND PUBLIO TIBI, Petitioners, v. HEIRS OF PONCIANO ALMEDA IN
SUBSTITUTION OF ORIGINAL DEFENDANT PONCIANO ALMEDA, INTESTATE ESTATE OF SPOUSES
PONCIANO AND EUFEMIA PEREZ-ALMEDA AND THE REGISTER OF DEEDS OF TAGAYTAY
CITY, Respondent.

A notarized Deed of Absolute Sale has in its favor the presumption of regularity, and it carries the
evidentiary weight conferred upon it with respect to its due execution.49 It is admissible in evidence without
further proof of its authenticity and is entitled to full faith and credit upon its face.50 Thus, a notarial
document must be sustained in full force and effect so long as he who impugns it does not present strong,
complete and conclusive proof of its falsity or nullity on account of some flaws or defects.51

Absent evidence of falsity so clear, strong and convincing, and not merely preponderant, the presumption of
regularity must be upheld.52 The burden of proof to overcome the presumption of due execution of a
notarial document lies on the party contesting the same.