People v. De Leon
REITERATIONFacts
The Antecedents: Bernardino B. Blancaflor, a former temporary stenographer, was required to submit transcripts of stenographic notes taken on October 20, 1973, in Criminal Cases Nos. 633-P and 935-P, and to show cause for failure to do so by June 17, 1976. Procedural History: Blancaflor failed to comply, leading to a P200 fine. He later moved to lift the fine, claiming the notes might have been lost due to a fire in his residence on December 15, 1974, and suggested retaking testimony. The matter was referred to the Executive Judge for investigation. Blancaflor failed to comply with the directive to appear or submit an affidavit. The Executive Judge found that Blancaflor violated Section 17, Rule 136 of the Rules of Court by failing to deliver his stenographic notes to the clerk of court immediately after the session. The Executive Judge recommended a reprimand. Blancaflor was again required to comment on the report and show cause, but he failed to do so. His temporary appointment expired on January 15, 1975, and he was reappointed in 1976, serving in North Cotabato. The Petition: The Supreme Court considered the report and Blancaflor's continued non-compliance.
Issue(s)
Whether Bernardino B. Blancaflor should be subjected to disciplinary action for his failure to submit transcripts of stenographic notes. Whether the fine imposed upon Blancaflor should be lifted. Whether Blancaflor violated Section 17, Rule 136 of the Rules of Court.
Ruling
The Court resolved to impose severe censure upon Bernardino B. Blancaflor for the loss of his stenographic notes and ordered that the P200 fine previously imposed shall stand. Furthermore, considering his inefficiency, his temporary appointment as stenographer shall not be renewed upon its expiration on March 6, 1979. The Presiding Judge of the Court of First Instance of North Cotabato was directed to require Blancaflor to transcribe his notes before his appointment expires.
Ratio Decidendi
On the disciplinary action for failure to submit transcripts: The Court found that Bernardino B. Blancaflor, a former temporary stenographer, failed to comply with repeated directives to submit transcripts of stenographic notes from Criminal Cases Nos. 633-P and 935-P. His explanation that the notes might have been lost due to a fire was not substantiated by his failure to appear or submit an affidavit when directed by the Executive Judge. This failure constitutes a violation of Section 17, Rule 136 of the Rules of Court, which mandates the immediate delivery of stenographic notes to the clerk of court. The Court noted his prior instances of inefficiency in submitting transcripts in other cases, further supporting the need for disciplinary measures. Therefore, severe censure was deemed appropriate. On lifting the fine and the violation of Section 17, Rule 136: The Court maintained the P200 fine imposed on Blancaflor. His claim of lost notes, even if true, does not absolve him from the consequences of failing to comply with his duty under Section 17, Rule 136 of the Rules of Court. This rule requires stenographers to deliver their notes to the clerk of court promptly after the session. His failure to do so, and his subsequent inability to produce the transcripts, demonstrates a clear disregard for this procedural requirement. The investigation conducted by the Executive Judge confirmed his non-compliance with court directives and the rules. Consequently, the fine stands, and he is severely censured. On the renewal of his temporary appointment: Considering Blancaflor's inefficiency, as evidenced by his failure to submit transcripts in multiple cases including Arahan vs. Aboitiz Shipping Corporation, Sobrepeña vs. Sobrepeña, People vs. Libutan, and Navarro vs. Vibal, the Court resolved not to renew his temporary appointment as stenographer when it expires on March 6, 1979. This decision reflects the Court's concern for the efficient administration of justice and the need for competent personnel. The Presiding Judge of his current station was instructed to ensure he transcribes his notes before his term ends, mitigating further prejudice.
Main Doctrine
A stenographer who fails to submit transcripts of stenographic notes as required by the Rules of Court and court directives, and whose failure is attributed to the loss of said notes, may be subjected to disciplinary action including a fine, reprimand, and non-renewal of temporary appointment.