In the Philippine legal system, the adage "justice delayed is justice denied" is not merely a cliché but a constitutional concern. To address the perennial problem of court congestion, the 1987 Constitution, the Rules of Court, and various administrative circulars from the Supreme Court prescribe specific timelines within which judges and justices must resolve motions and render judgments.
I. Constitutional Mandates: The Outer Limits
The 1987 Philippine Constitution (Article VIII, Section 15) sets the maximum periods for the resolution of cases or matters submitted for decision. These periods are counted from the date the case is "submitted for decision"—meaning the date the last pleading, brief, or memorandum required by the Rules or the court has been filed.
| Court Level | Prescribed Period for Decision |
|---|---|
| Supreme Court | 24 months |
| All lower collegiate courts (CA, CTA, Sandiganbayan) | 12 months |
| All other lower courts (RTC, MeTC, MTCC, MTC, MCTC) | 3 months (90 days) |
Note: Failure to decide within these periods does not deprive the court of jurisdiction, but it may subject the erring judge to administrative sanctions.
II. Timelines for Resolutions of Motions
Not every filing is a final judgment. Motions—applications for relief other than by a pleading—have their own distinct timelines under the 2019 Proposed Amendments to the 1997 Rules of Civil Procedure.
1. Litigated Motions
These are motions that require notice and a hearing (or at least the opportunity for the opposing party to comment).
- Opposition/Comment: The adverse party has 5 calendar days from receipt to file an opposition.
- Resolution: The court must resolve the motion within 15 calendar days from the receipt of the opposition or the expiration of the period to file one.
2. Prohibited Motions
To expedite proceedings, the rules strictly prohibit certain motions, such as motions for extensions of time (except for certain instances) or motions for reconsideration of interlocutory orders (in summary procedure).
3. Motions for Reconsideration (Final Orders)
- Filing: A party may file a motion for reconsideration within 15 days from notice of the judgment or final order.
- Resolution: The court must resolve it within 30 days from the time it is submitted for resolution.
III. Timelines for Judgments in Specific Proceedings
The nature of the case often dictates a more accelerated timeline than the standard 90-day rule for lower courts.
1. The Rule on Summary Procedure
For small claims and certain ejectment cases, the timelines are significantly compressed:
- Judgment: The court should render judgment within 30 days after the receipt of the last affidavits and position papers.
2. Criminal Cases
Under the Revised Guidelines for Continuous Trial of Criminal Cases, the timelines are strictly monitored:
- Promulgation of Judgment: The judge must promulgate the decision within 90 days from the time the case is submitted for decision.
- Motion for Reconsideration/New Trial: Must be resolved within a non-extendible period of 30 days from submission.
IV. When is a Case "Submitted for Decision"?
A common point of contention is exactly when the clock starts ticking. Under Supreme Court Administrative Circular No. 28-91, a case is deemed submitted for decision:
- In civil cases: Upon the filing of the last pleading, brief, or memorandum.
- In criminal cases: Upon the termination of the trial or the filing of the last memorandum.
If the judge requires the parties to file memoranda, the case is only "submitted" once the period to file them has expired, even if the parties fail to actually file them.
V. Consequences of Non-Compliance
The Supreme Court, through the Office of the Court Administrator (OCA), monitors these deadlines through monthly reports.
- Administrative Liability: Judges who fail to decide cases within the 90-day period may be found guilty of "Gross Inefficiency" or "Undue Delay in Rendering a Decision."
- Withholding of Salaries: In many instances, the certification required for a judge to collect their salary includes a statement that they have decided all cases/motions within the 90-day period.
- Extensions: If a judge cannot decide a case within the period due to heavy caseloads or illness, they must file a request for an extension with the Supreme Court before the original deadline expires.
VI. Summary Table of Key Deadlines
| Action | Deadline |
|---|---|
| Motion Resolution (General) | 15 days from opposition/expiration of period |
| RTC/MTC Judgment | 90 days from submission |
| Summary Procedure Judgment | 30 days from submission |
| Motion for Reconsideration (Civil) | 30 days to resolve |
| Promulgation (Criminal Trial) | 90 days from submission |