Guitante v. Bantuas
REITERATIONFacts
The Antecedents: Martino Guitante filed a verified complaint against respondent District Judge Tago Bantuas for failing to decide Civil Case No. 4018 within the ninety-day period required by law. The case, "Rosario Bandico v. Antonio Tan, et. al.", was filed on October 13, 1972, and the trial concluded on May 4, 1976. Parties were given time to file memoranda, with the plaintiff's reply memorandum filed on February 11, 1977. As of May 31, 1977, approximately 110 days had passed since the case was submitted for decision without a definite resolution. Procedural History: The complaint was filed by Martino Guitante on behalf of Antonio C. Tan. The respondent Judge admitted the delay but attributed it to the non-transcription of stenographic notes for a complicated case. The Petition: The complaint charged the respondent Judge with failure to decide Civil Case No. 4018 within the statutory ninety-day period.
Issue(s)
Whether the respondent Judge failed to decide Civil Case No. 4018 within the ninety-day period required by law. Whether the delay in the transcription of stenographic notes and the complexity of the case constitute valid defenses for the respondent Judge's failure to decide within the reglementary period.
Ruling
The respondent Judge is hereby reprimanded and admonished that a repetition of the same offense shall be dealt with more severely. A copy of the resolution shall be filed in the personal records of the respondent Judge.
Ratio Decidendi
On the issue of failure to decide within the ninety-day period: The respondent Judge admitted that Civil Case No. 4018 was not decided within the ninety-day period provided by law. This admission renders a formal investigation of the charge unnecessary. The duty of a judge to decide cases within the prescribed period is a constitutional and statutory mandate. Such failure constitutes a violation of this duty, irrespective of the circumstances surrounding the case. On whether delay in transcription and case complexity are valid defenses: The Court held that the circumstances of late submission of the transcript of stenographic notes and the case being complicated do not constitute valid defenses for the respondent Judge's failure to decide within the ninety-day period. The Court reiterated the principle that the period for deciding a case commences from the date it is submitted for decision, not from the completion of the transcript. Judges are expected to take down their own notes of salient portions of the hearing and proceed with decision preparation without solely relying on transcribed notes. The Court emphasized that the ninety-day period should be adhered to with or without the transcribed stenographic notes.
Main Doctrine
The failure of a judge to decide a case within the mandated ninety-day period, even if the case is complicated or there is delay in the transcription of stenographic notes, constitutes a violation of the constitutional and statutory duty of a judge, warranting administrative sanction.