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24 months to decide a case: not an inflexible rule – SC

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By Rey Panaligan

The Supreme Court (SC) has declared that while the Constitution provides that it should decide cases within 24 months, the time limit is merely a “directive to ensure this court’s prompt resolution of cases and should not be interpreted as an inflexible rule.”

In a resolution written by Associate Justice Marvic Mario Victor F. Leonen, the SC said “while the 24-month period provided under the 1987 Constitution is persuasive, it does not summarily bind this Court to the disposition of cases brought before it.”

However, it pointed out that “the prescribed time limit should not be ignored as to render nugatory the spirit which breathes life to the letter of the 1987 Constitution.”

“Ultimately, courts must strike an objective and reasonable balance in disposing cases promptly, while maintaining judicious tenacity in interpreting and applying the law,” it stressed.

With the ruling, the SC dismissed the complaint filed against former Chief Justice Teresita J. Leonardo de Castro for gross ignorance of the law, gross inefficiency, gross misconduct, gross dishonesty, and conduct prejudicial to the best interest of the service.

The SC’s public information office (PIO) said the complaint was filed by Elvira N. Enalbes, Rebecca H. Angeles, and Estelita B. Ocampo who alleged that De Castro failed to decide, despite the lapse of more than five years, two separate petitions filed by Spouses Eligio P. Mallari and Marcelina I. Mallari in 2012 and 2013, respectively.

The PIO said that in dismissing the complaint for lack of a prima facie case, the SC said: “To hold a magistrate administratively liable for gross ignorance of the law, it is not enough that his or action was erroneous; it must also be proven that it was driven by bad faith, dishonesty, or ill motive.”

The PIO summary also stated:

“The Court ruled that complainants’ arguments, which relied on Article VIII, Section 15 of the 1987 Constitution requiring the Supreme Court to decide on cases within 24 months from their submission, lack merit.

“It noted that as stated in the 1987 Constitution and the Internal Rules of Court, the reckoning of the 24-month period begins only when the last pleading, brief, or memorandum has been submitted before it.

“The Court stressed that it, being the court of last resort, ‘should be given an ample amount of time to deliberate on cases pending before it. Ineluctably, leeway must be given to magistrates for them to thoroughly review and reflect on the cases assigned to them.

“The Court note that all matters brought before it involves rights which are legally demandable and enforceable. It would be at the height of injustice if cases were hastily decided on at the risk of erroneously dispensing justice.

“The Court stressed that it, being the court of last resort, ‘should be given an ample amount of time to deliberate on cases pending before it. Ineluctably, leeway must be given to magistrates for them to thoroughly review and reflect on the cases assigned to them.’

“The Court note that all matters brought before it involves rights which are legally demandable and enforceable. It would be at the height of injustice if cases were hastily decided on at the risk of erroneously dispensing justice.”

Lastly, the PIO said that while the complaint could have been dismissed as academic with the retirement of De Castro, the SC opted to rule on its merits.

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