Data Privacy Cases Digest
Data Privacy Cases Digest
18-5805), (2023)
Analysis:
1. Case Identification: A.C. No. 13678 (Formerly CBD Case No. 18-5805),
(2023) [J1] is a disbarment case titled "EHRENFREL C. AZARRAGA,
COMPLAINANT, VS. ATTY. EDUARDO L. JALBUNA, RESPONDENT."
2. Key Issues: The case involved allegations of: a) Violations of the 2004
Rules on Notarial Practice b) Violation of the Data Privacy Act of 2012 c)
Violation of Canon 1, Rule 1.01 of the Code of Professional
Responsibility
3. Court's Findings: a) Notarial Practice: The court found Atty. Jalbuna
guilty of notarial lapses. b) Data Privacy Act: The court ruled in Atty.
Jalbuna's favor, stating his actions were lawful during a legal
proceeding.
4. Penalties Imposed: a) Revocation of Atty. Jalbuna's Notarial
Commission b) Two-year disqualification from being a notary public c)
Three-month suspension from law practice
Conclusion: A.C. No. 13678 (2023) [J1] emphasizes the importance of integrity in
notarial practice. While the court found Atty. Jalbuna guilty of notarial violations, it
dismissed charges under the Data Privacy Act. This case underscores the
Supreme Court's commitment to maintaining high standards in the legal
profession, particularly in notarial duties.
Analysis:
Analysis:
Conclusion: The Supreme Court's decision in G.R. No. 226244 (2021) [J1]
emphasizes the importance of properly establishing just cause for termination,
especially when alleging loss of trust and confidence. The Court's ruling suggests
that employers must carefully consider an employee's position and the nature of
the alleged violation before terminating employment on these grounds. This case
also highlights the need for clear company policies regarding the handling of
sensitive information.