I. Introduction

In the Philippines, medical certificates are indispensable documents in various legal, administrative, and employment contexts. They serve as formal attestations by licensed physicians regarding an individual's health status, fitness for work, medical history, or specific conditions. These certificates often require notarization to enhance their evidentiary weight, particularly when submitted to government agencies, courts, or private entities that demand authenticated proof.

A persistent question among practitioners, notaries public, and the public is whether a medical certificate can be notarized without an accompanying certified true copy of the original. This inquiry intersects with the 2004 Rules on Notarial Practice (A.M. No. 02-8-13-SC, as amended), the Civil Code provisions on public documents, and jurisprudential interpretations of authenticity and due execution.

This article exhaustively examines the legal framework governing notarization of medical certificates, the role of certified true copies, permissible notarial acts, exceptions, procedural requirements, liabilities, and practical implications—all within the exclusive context of Philippine law.

II. Nature of a Medical Certificate as a Document

A. Classification: Private Document Ab Initio

A medical certificate issued by a physician in the ordinary course of professional practice is a private document. It does not emanate from a public officer acting in an official capacity, nor is it inherently imbued with public faith under Article 1358 of the Civil Code.

Rationale: The physician acts as a private practitioner, not as a government functionary. The certificate reflects a professional opinion, not an official act.
Consequence: As a private document, its genuineness and due execution must be proved in court unless acknowledged before a notary public (Rule 132, Section 20, Revised Rules on Evidence).

B. Elevated Status Upon Notarization

When a medical certificate is acknowledged or authenticated by a notary public, it becomes a public document for evidentiary purposes:

“Ackowledged documents are public documents and are admissible in evidence without further proof of their due execution and genuineness.”
(Sps. Sabordo v. Villarosa, G.R. No. 171041, November 22, 2007)

Thus, notarization transforms the certificate into a notarial public document, enjoying the presumption of regularity.

III. The 2004 Rules on Notarial Practice: Core Principles

The Supreme Court’s 2004 Rules on Notarial Practice (A.M. No. 02-8-13-SC, effective August 1, 2004, as amended) is the primary regulatory framework. Key provisions relevant to medical certificates include:

Rule	Provision	Application to Medical Certificates
Rule II, Sec. 1	Notarial acts: (a) acknowledgments, (b) oaths and affirmations, (c) jurats, (d) signature witnessing, (e) copy certifications	Medical certificates are typically acknowledged or subject to jurat if containing a verification.
Rule II, Sec. 2(b)	Copy Certification: Notary may certify that a copy is a true reproduction of the original only if the original is a public document or is exhibited to the notary.	Critical limitation: Private documents (like original medical certificates) cannot be copy-certified unless already public (e.g., previously notarized).
Rule IV, Sec. 2	Competent Evidence of Identity: Signatory must present valid ID; notary must record details.	Physician or patient (if signing) must be personally known or present valid ID.
Rule VI, Sec. 1	Notarial Register: Every notarial act must be recorded with full details.	Mandatory even for simple acknowledgments.

IV. Can a Medical Certificate Be Notarized Without a Certified True Copy?

Direct Answer: YES — but only via ACKNOWLEDGMENT of the ORIGINAL.

The original medical certificate can be acknowledged by the issuing physician (or the patient, if applicable) without requiring a certified true copy, subject to strict conditions.

Legal Basis: Acknowledgment of Private Documents

Rule II, Section 1(a): Acknowledgment — “a notarial act whereby the person appearing before the notary public acknowledges that the signature on the document is his own voluntary act and deed.”
No requirement for certified true copy in acknowledgment.
The original document must be presented to the notary.
The signatory (usually the physician) must:
1. Personally appear;
2. Be identified via competent evidence;
3. Acknowledge the signature as voluntary.

Example: Dr. Reyes issues a medical certificate for Mr. Cruz’s pre-employment requirement. Dr. Reyes brings the original certificate to Atty. Santos (notary). Dr. Reyes signs the acknowledgment clause:
“BEFORE ME, this 13th day of November 2025, personally appeared Dr. Juan Reyes, with PRC ID No. 123456, known to me and to me known to be the same person who executed the foregoing medical certificate and acknowledged to me that the same is his free and voluntary act and deed.”
No certified true copy needed.

V. When Is a Certified True Copy Required?

A certified true copy is mandatory in the following scenarios:

Scenario	Requirement	Legal Basis
Copy Certification of a Public Document	Original public document must be presented; notary certifies copy as accurate.	Rule II, Sec. 2(b)
Submission to Government Agencies Requiring “Authenticated Copy” (e.g., DFA Red Ribbon, PRC, POEA)	Original + notarized copy, or CTC from issuing authority (hospital/clinic) + notarization	Administrative practice; DFA Circulars
Multiple Submissions of the Same Certificate	Original cannot be surrendered everywhere → notarized copies needed	Practical necessity

Key Rule: A private document (like an original medical certificate) cannot be copy-certified by a notary unless it has already been notarized (thus becoming public).

VI. Prohibited Acts and Common Misconceptions

A. Notary Cannot Certify Copy of Original Medical Certificate

Invalid: Notary stamps “Certified True Copy” on a photocopy of an unnatarized medical certificate.
Reason: The original is private; notary has no authority to certify its reproduction unless it is a public document.
Violation: Rule II, Sec. 2(b) — constitutes notarial misconduct.

B. Notary Cannot Notarize a Photocopy Without Original

Invalid: Physician sends photocopy; notary notarizes it.
Violation: Rule IV, Sec. 2 — failure of personal appearance and document inspection.

C. Clinic/Hospital-Issued “Certified True Copy” Is Not Notarial

A hospital’s “Certified True Copy” stamp (signed by records custodian) is administrative, not notarial.
It may be notarized if the custodian acknowledges it, but this is rare.

VII. Step-by-Step Guide: Proper Notarization of Medical Certificate

Option 1: Acknowledgment of Original (No CTC Needed)

Physician prepares original medical certificate with signature.
Physician personally appears before notary.
Presents valid ID.
Signs acknowledgment clause in notary’s presence.
Notary records in notarial register.
Notary affixes seal and signature.

Result: Original is now a notarial public document. Photocopies may be made, but not certified by notary unless re-presented.

Option 2: Notarization + Copy Certification (For Multiple Use)

Step 1: Original is acknowledged (as above).
Step 2: Original is presented again to same or another notary.
Step 3: Notary certifies photocopies as true reproductions of the now-public original.

Result: Notarized original + certified true copies.

VIII. Special Cases and Exceptions

Case	Rule	Procedure
Patient Signs the Certificate (e.g., consent-based)	Patient must acknowledge	Same as physician
Corporate Medical Certificate (company doctor)	Issued under company seal	May be acknowledged by doctor or HR
Electronic Medical Certificate	Not yet recognized for notarization	Must be printed and acknowledged
Lost Original	Impossible to notarize copy	Must secure new original from physician

IX. Liabilities for Improper Notarization

Violation	Penalty	Authority
Notarizing without personal appearance	Disbarment, fine	A.M. No. 02-8-13-SC, Rule XII
False copy certification	Suspension, revocation of commission	Ibid.
Failure to require ID	Administrative sanction	Ibid.

Landmark Case: Dela Cruz v. Atty. Zaballero (A.C. No. 7297, June 25, 2007) — notary suspended for certifying copy without original.

X. Practical Recommendations

Always notarize the ORIGINAL via acknowledgment.
Secure multiple originals from the physician if needed for different agencies.
For authenticated copies (DFA, etc.), follow:
Original → Notarized → CTC by notary → DFA authentication.
Clinics should issue duplicate originals with unique control numbers.
Notaries must maintain photocopy of notarized original in files (best practice, though not required).

XI. Conclusion

Yes, a medical certificate can be notarized without a certified true copy — provided the original is presented for acknowledgment by the signatory before a notary public. This is the standard, lawful, and most efficient method under the 2004 Rules on Notarial Practice.

However, copy certification is impossible without prior notarization of the original. Notaries who certify photocopies of unnotarized medical certificates commit a serious violation punishable by suspension or disbarment.

For practitioners and the public, the rule is clear: notarize the original, then certify copies if needed. This dual-step process ensures compliance, authenticity, and evidentiary reliability in all legal and administrative proceedings.

References:

2004 Rules on Notarial Practice (A.M. No. 02-8-13-SC)
Civil Code of the Philippines (Arts. 1358, 1173)
Revised Rules on Evidence (Rule 132, Sec. 20)
Supreme Court Decisions: Sabordo v. Villarosa, Dela Cruz v. Zaballero