August 16, 2017

A.C. No. 8574

CARMELO IRINGAN, Complainant,
vs.
ATTY. CLAYTON B. GUMANGAN,, Respondent.

It is worthy to mention that any defect in the notarization of the Contract of Lease did not affect its
validity and it continued to be binding between the parties to the same, namely, Renato and
Carmelo.

SALIENT RULING:

The irregularity in the notarization was not fatal to the validity of the Contract of Lease since
the absence of such formality would not necessarily invalidate the lease, but would merely
render the written contract a private instrument rather than a public one. 28