In re: Laura A. Dahdah de Surillo, 2023 TSPR 124

Complainant Juan Manuel Ponce Fantauzzi alleged that Notary Laura A. Dahdah de Surillo authorized two permuta (exchange) deeds that described the grantor as owner of entire parcels, omitting Ponce Fantauzzi’s 50% pro indiviso interest.
Dahdah admitted she authorized the Escrituras Núm. 50 and 51 (14‑Aug‑2020), knew of Ponce’s interest, did not have a title study before notarizing, and later attempted corrective instruments; Ponce refused to ratify the corrections.
When Ponce refused to sign the rectifications, Dahdah executed Escritura Núm. 130 (7‑Oct‑2021) to revoke the permutas and withdrew the prior deeds from the Property Registry.
ODIN investigated and concluded Dahdah certified false facts, violated Art. 2 of the Notarial Law, Art. 131 of the Property Registry Law, and Canons 18, 35 and 38 of the Code of Professional Ethics, recommending a three‑month suspension.
Dahdah defended the omissions as inadvertent, isolated, and caused in part by COVID‑19 precautions that prevented access to her office and files; the Court rejected these mitigations.
The Supreme Court suspended Dahdah’s notarial practice for three months, ordered client notifications and return of files/fees, cancelled her bond, and directed seizure of her notarial seal and record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the notary certified a false fact by stating grantor owned entire parcels	Deeds falsely represented full ownership; certifying that is a false notarial act	Omission was inadvertent, not intentional; isolated error	Court: She certified a false fact; violation of Art. 2 and professional canons
Whether notarizing without a title study breached notarial duties	Notary must review registral antecedents/title study before authorizing deeds	Files were at office; she avoided office due to COVID‑19 fear; attempted later corrections	Court: Failure to perform title study violated fe pública and Canon 18; justification rejected
Whether transfers of specific shares in pro indiviso property were registrable	Inscription of specific quotas requires prior adjudication or public deed with all co‑owners’ consent (Art. 131)	Attempted corrective instruments and later revocation show remedial intent	Court: Deeds violated Art. 131; registration was improper
Appropriate disciplinary sanction	ODIN: three‑month suspension considering lack of prior discipline and remedial revocation	Dahdah: mitigate due to isolation, pandemic, long good record, isolated incident	Court: Adopted three‑month suspension and ordered ancillary remedies (client notice, return files/fees, bond cancellation, seizure of seal)

In re Pagani Padró, 198 DPR 812 (2017) (authorizing a deed without verifying registral antecedents via a title study violates notarial duty)
In re Pagán Díaz, 198 DPR 398 (2017) (principle of fe pública notarial and consequences of certifying untrue facts)
In re Vargas Velázquez, 193 DPR 681 (2015) (notary must know title history before authorizing instruments)
In re Villalona Viera, 206 DPR 360 (2021) (certifying false facts undermines fe pública and warrants severe discipline)
In re Maldonado De Jesús, 208 DPR 601 (2022) (notarial competence and diligence obligations under the Notarial Law and Canon 18)
Vázquez González, 194 DPR 688 (2016) (false or misleading statements in legal instruments implicate Canon 35 and disciplinary sanction)