Posted by: Ana R. Bonita on July 18, 2018
FACTS:
Submitted to the Court for consideration was a resolution of the Board of Governors, Integrated Bar of the Philippines (hereafter, the IBP) recommending an inquiry into the causes of delays in the resolution of incidents and motions and in the decision of cases pending before the Sandiganbayan dated July 29, 2000.
Particularly, the IBP maintained that the Supreme Court Administrative Circular No. 10-94 which requires all Regional Trial Courts, Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts to submit to the Supreme Court a bi-annual report indicating the title of the case, its date of filing, the date of pre-trial in civil cases and arraignment in criminal cases, the date of initial trial, the date of last hearing and the date that the case is submitted for decision, and to post, in a conspicuous place within its premises, a monthly list of cases submitted for decision should also be imposed upon the Sandiganbayan, considering that the Sandiganbayan is also a trial court.
On August 8, 2000, the Court required Sandiganbayan Presiding Justice Francis E. Garchitorena to comment on the letter of the IBP and to submit a list of all Sandiganbayan cases pending decision, or with motion for reconsideration pending resolution, indicating the dates they were deemed submitted for decision or resolution. On September 27, 2000, complying with the order, Presiding Justice Francis E. Garchitorena submitted a report (hereafter, the compliance) admitting a number of cases submitted for decision and motion for reconsideration pending resolution before its divisions.
Thus, the Sandiganbayan has a total of four hundred fifteen (415) cases for decision remaining undecided long beyond the reglementary period to decide, with one case submitted as early as May 24, 1990, and motion for reconsideration which has remained unresolved over thirty days from submission.
On October 26, 2000, the IBP submitted its reply to the compliance stating: First, that it was not in a position to comment on the accuracy of the compliance; nonetheless, it showed that there was much to be desired with regard to the expeditious disposition of cases, particularly in the Sandiganbayan's First Division, where cases submitted for decision since 1990 remained unresolved. Second, the compliance did not include pending motions, and it is a fact that motions not resolved over a long period of time would suspend and delay the disposition of a case. Third, since the Sandiganbayan is a trial court, it is required to submit the same reports required of Regional Trial Courts. Fourth, the Constitution states that, all lower collegiate courts must decide or resolve cases or matters before it within twelve (12) months from date of submission; however, the Sandiganbayan, as a trial court, is required to resolve and decide cases within a reduced period of three (3) months like regional trial courts, or at the most, six (6) months from date of submission.
ISSUE:
Whether or not the Rule-Making Power of the Supreme Court enunciated under Administrative Circular No. 1094 is applicable to the Sandiganbayan.
HELD:
Applicability of SC Adm. Circular No. 10-94.-- Supreme Court Circular No. 10-94 applies to the Sandiganbayan.
This Court has consistently impressed upon judges (which includes justices) to decide cases promptly and expeditiously on the principle that justice delayed is justice denied. Decision making is the primordial and most important duty of the member of the bench. Hence, judges are enjoined to decide cases with dispatch. Their failure to do so constitutes gross inefficiency that warrants disciplinary sanction, including fine, suspension and even dismissal.
The rule particularly applies to justices of the Sandiganbayan. Delays in the disposition of cases erode the faith and confidence of our people in the judiciary, lower its standards, and bring it into disrepute. Delays cannot be sanctioned or tolerated especially in the anti-graft court, the showcase of the nation's determination to succeed in its war against graft.
