Marcelino v. Cruz, Jr.
REITERATIONFacts
1. The Antecedents: Petitioner Bernardino Marcelino was charged with the crime of rape before the Court of First Instance of Rizal, Branch XII. The trial concluded with the accused resting his case on August 4, 1975, after which both parties moved for time to submit their respective memoranda. 2. Procedural History: Following the submission of memoranda, the trial court was granted thirty days to decide the case. The decision was dated and filed with the deputy clerk of court on November 28, 1975, eighty-five days after the case was deemed submitted. Promulgation was scheduled for December 2, 1975, but was repeatedly postponed. The petitioner's counsel first raised the issue of the trial court's loss of jurisdiction due to the failure to decide within the constitutionally mandated ninety-day period on December 2, 1975. The present petition was filed on January 12, 1976, leading to a temporary restraining order from the Supreme Court on January 16, 1976. 3. The Petition: This case involves a petition for prohibition and writ of habeas corpus, seeking to prevent the promulgation of the decision in Criminal Case No. C-5910 and to secure the petitioner's release from detention. The core argument is that the respondent trial court lost jurisdiction over the case due to its failure to render a decision within the ninety-day period stipulated by Section 11(1) of Article X of the 1973 Constitution. The petitioner contends that this constitutional directive is mandatory and its violation results in a loss of jurisdiction.
Issue(s)
Whether the failure of the respondent trial court to decide the case within the ninety (90) day period from submission thereof resulted in the loss of its jurisdiction over the case. Whether the ninety-day period prescribed by Section 11(1) of Article X of the 1973 Constitution is mandatory or directory.
Ruling
The petition is dismissed, and the restraining order is lifted. The successor of the deceased respondent judge is ordered to decide Criminal Case No. C-5910 on the basis of the record thereof within ninety (90) days from the time the case is raffled to him.
Ratio Decidendi
On the issue of loss of jurisdiction due to failure to decide within ninety (90) days: The Court held that the failure to decide a case within the ninety-day period prescribed by Section 11(1) of Article X of the 1973 Constitution does not result in the loss of jurisdiction of the court over the case. The Court found that the decision was rendered on November 28, 1975, which was eighty-five (85) days from September 4, 1975, the date the case was deemed submitted for decision. This falls within the three-month period stipulated by the Constitution. The Court clarified that the "rendition of judgment" refers to the filing of the signed decision with the clerk of court, not its promulgation. The promulgation date, which necessarily comes later due to notice requirements, cannot be the reckoning date for determining compliance with the constitutional period. Therefore, the trial court did not lose jurisdiction. On whether the ninety-day period is mandatory or directory: The Court ruled that the ninety-day period prescribed by Section 11(1) of Article X of the 1973 Constitution is merely directory and not mandatory. While constitutional provisions are generally construed as mandatory, an exception exists when a contrary construction would lead to absurd, impossible, or mischievous consequences. The Court reasoned that the phrase "unless reduced by the Supreme Court" in the provision indicates that the period is subject to modification by the Supreme Court, implying it relates to matters of procedure. Furthermore, a strict application leading to loss of jurisdiction would make courts instruments of unresolved causes, an absurd situation not intended by the framers. The Court noted its liberal practice of allowing judges additional time for meritorious reasons, as enforcing the strict letter of the law would cause less injury to the general public by disregarding it than by enforcing it. The Court cited authorities holding that statutes requiring rendition of judgment "forthwith" or "immediately" are often held directory, and this principle applies equally to the constitutional provision in question.
Main Doctrine
The failure of a judge to decide a case within the ninety-day period prescribed by the Constitution does not result in the loss of jurisdiction of the court over the case, as the said period is merely directory and not mandatory. The rendition of judgment, which refers to the filing of the signed decision with the clerk of court, is the operative act, not its promulgation.