An improperly notarized document cannot be considered a public document and will not enjoy the presumption of its due execution and authenticity (DELA RAMA vs. PAPA, G.R. No. 142309, January 30, 2009, Second Division, Tinga, J.).
Be that as it may, while notarized document enjoys the presumption of regularity, the fact that a deed is notarized is not guarantee of the validity of its contents (SAN JUAN vs. OFFRIL, G.R. No. 154609, April 24, 2009, Second Division, Tinga, J.).
