Saturday, March 22, 2014

Espinosa v.Atty. Omana, A.C. No. 9081, October 12, 2011

FACTS: On 17 November 1997, Rodolfo Espinosa and his wife Elena Marantal sought Omana’s legal advice on whether they could dissolve their marriage and live separately. Omana prepared a document entitled “Kasunduan Ng Paghihiwalay.” Espinosa and Marantal started implanting the conditions of the said contract. However, Marantal took custody of all their children and took possession of most of the conjugal property. Espinosa sought the advice of Glindo, his fellow employee who is a law graduate, who informed him that the contract executed by Omana was not valid. They hired the services of a lawyer to file a complaint against Omana before the IBP-CBD. Omana denied that she prepared the contract. She admitted that Espinosa went to see her and requested for the notarization of the contract but she told him that it was illegal. Omana alleged that Espinosa returned the next day while she was out of the office and managed to persuade her part-time office staff to notarize the document. Her office staff forged her signature and notarized the contract.

ISSUE: W/N Omaña violated the CPR in notartizing the “Kasunduan Ng Paghihiwalay.” W/N the Kasunduaan ng Paghihiwalay is valid.


HELD: SC has ruled that the extrajudicial dissolution of the conjugal partnership without judicial approval is void. The Court has also ruled that a notary public should not facilitate the disintegration of a marriage and the family by encouraging the separation of the spouses and extrajudicially dissolving the conjugal partnership, which is exactly what Omaña did in this case.

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