G.R. No. A.M. No. 1638-CFI January 28, 1980
MARTINO GUITANTE, complainant, vs. HON. TAGO BANTUAS, District Judge of the Court of First Instance of Misamis Oriental, Branch II, Cagayan de Oro City, respondent.

FACTS

Complainant Martino Guitante, on behalf of Antonio C. Tan, charged respondent Judge Tago Bantuas with failure to decide Civil Case No. 4018 within the 90-day period mandated by law. The case was filed in 1972, and trial concluded on May 4, 1976. The parties were then given time to file memoranda, with the final reply memorandum submitted by the plaintiff on February 11, 1977. The complaint, filed on May 31, 1977, alleged that approximately 110 days had elapsed since the case was deemed submitted for decision without a ruling from the respondent judge.
Respondent Judge admitted the delay in his answer. He offered two explanations: first, that the stenographic notes had not been transcribed on time, and second, that the case was legally complicated, necessitating his reliance on the full transcript before he could prepare a decision.

ISSUE

Whether the reasons proffered by respondent Judge—the non-transcription of stenographic notes and the complexity of the case—constitute a valid justification for his failure to decide the case within the 90-day reglementary period.

RULING

The Court found respondent Judge administratively liable. His explanations were rejected as invalid defenses. The legal logic is anchored on a clear and mandatory constitutional and statutory directive. The 90-day period for deciding cases, under Article X, Section 11 of the 1973 Constitution and Section 5 of the Judiciary Act ( Republic Act No. 296 ), is reckoned from the date the case is submitted for decision. The Court, citing Lawan v. Moleta, explicitly ruled that this period commences upon submission and is not tolled by the absence of transcribed stenographic notes.
The ruling establishes that judges have a positive duty to manage their caseload to comply with this deadline. They are instructed to take their own notes during hearings to facilitate timely decision-writing. The complexity of a case does not excuse non-compliance; it merely requires diligent and efficient management from the judge. The Court noted that by the time of his answer in August 1979, respondent had already decided the case. However, his prior delay constituted a breach of duty. Accordingly, the Court REPRIMANDED Judge Bantuas and sternly warned that a repetition would be met with a more severe penalty.