In the Philippine legal system, the adage "justice delayed is justice denied" is not merely a moral sentiment but a constitutional command. To prevent the indefinite suspension of cases and to ensure the speedy disposition of justice, the 1987 Constitution, the Rules of Court, and various administrative circulars prescribe strict timelines for judges and justices to resolve motions and render decisions.
Failure to comply with these periods can lead to administrative sanctions for members of the bench, ranging from fines to dismissal from the service.
I. Constitutional Timelines
The 1987 Constitution provides the overarching framework for the prompt resolution of cases. Under Article VIII, Section 15, all cases or matters filed after the effectivity of the Constitution must be decided or resolved within the following periods from the date of submission:
- Supreme Court: Within twenty-four (24) months.
- Lower Collegiate Courts (e.g., Court of Appeals, Sandiganbayan, Court of Tax Appeals): Within twelve (12) months, unless reduced by the Supreme Court.
- Lower Courts (e.g., RTC, MeTC, MTCC, MTC, MCTC): Within three (3) months.
When is a case "submitted for decision"? A case or matter is deemed submitted for decision or resolution upon the filing of the last pleading, brief, or memorandum required by the Rules of Court or by the court itself.
II. Timelines for Lower Courts (RTC and First-Level Courts)
Beyond the constitutional three-month (90-day) mandate, the Rules of Court and the Revised Guidelines on Continuous Trial provide more granular deadlines for specific actions.
1. Rendering of Judgments
For Regional Trial Courts (RTC) and First-Level Courts (MTC/MeTC), the 90-day period is the absolute ceiling. In Criminal Cases, the court must promulgate the decision within 90 days from the time the case is submitted for decision.
2. Resolving Motions
- Ordinary Motions: Generally, motions must be resolved within 90 days from the time they are submitted for resolution.
- Motion for Reconsideration (MR): Under the Rules of Court, a motion for reconsideration of a final order or judgment must be resolved within 30 days from the time it is submitted for resolution.
- Motion to Dismiss / Motion to Quash: While the 90-day rule generally applies, the Revised Guidelines on Continuous Trial in Criminal Cases encourage faster resolution, often within 10 to 30 days depending on the complexity and the specific ground raised.
3. Summary Procedure
In cases falling under the Rules on Summary Procedure (e.g., small claims, certain ejectment cases, and light criminal offenses), the timelines are significantly tighter:
- The court must render judgment within 30 days after the receipt of the last affidavits and position papers, or the expiration of the period for filing them.
III. The "Certification" Requirement
To ensure accountability, the Constitution requires that any decision or resolution must contain a certification signed by the Chief Justice or the presiding judge. This certification states that the conclusions of the Court were reached in consultation before the case was assigned to a member for the writing of the opinion.
Furthermore, judges are required to submit a Monthly Report of Cases to the Office of the Court Administrator (OCA). This report includes a list of cases submitted for decision and those that have remained pending beyond the prescribed period.
IV. Exceptions and Extensions
While the periods are mandatory, the Supreme Court recognizes that "human impossibility" or heavy caseloads may occasionally hinder compliance.
- Request for Extension: A judge who finds themselves unable to decide a case within the 90-day period may ask the Supreme Court for an extension. This must be done before the original period expires. Valid reasons usually include poor health, a sudden influx of cases, or the complexity of the legal issues involved.
- Automatic Extensions: These do not exist. Without an express grant of extension from the Supreme Court, the lapse of the period constitutes a violation of the "Speedy Disposition of Cases" clause.
V. Consequences of Non-Compliance
The Supreme Court has consistently held that the failure of a judge to decide a case within the prescribed period is gross inefficiency. The penalties for such negligence include:
- Administrative Fines: Often equivalent to a portion of the judge’s salary.
- Withholding of Salaries: The "No Decision, No Salary" policy requires judges to certify that they have decided all cases submitted for 90 days before they can collect their pay.
- Suspension or Dismissal: In cases of habitual delays or "clogging of dockets" without valid justification.
- Impact on Promotion: Pending administrative cases or a history of delayed resolutions can disqualify a judge from being nominated to higher judicial positions by the Judicial and Bar Council (JBC).
VI. Summary Table of Prescriptive Periods
| Court Level | Type of Matter | Prescriptive Period |
|---|---|---|
| Supreme Court | Final Decision | 24 Months |
| Collegiate Courts (CA/SB/CTA) | Final Decision | 12 Months |
| Lower Courts (RTC/MTC) | Final Decision | 90 Days |
| Lower Courts | Motion for Reconsideration | 30 Days |
| Summary Procedure | Final Decision | 30 Days |
| Small Claims | Final Decision | Same day as hearing (or within 24 hours) |
VII. Procedural Significance for Litigants
For practitioners and litigants, these periods serve as a procedural safeguard. If a judge fails to resolve a motion or case within the period, the parties may file a "Motion to Render Decision" or, in extreme cases of protracted delay, a Petition for Mandamus to compel the performance of the ministerial duty to resolve the case. Additionally, a party may file an administrative complaint with the OCA for the judge's failure to comply with the constitutional timelines.