G.R. No. A.M. No. 99-8-286-RTC March 17, 2000
Report on the Judicial Audit Conducted in the Municipal Trial Court in Cities, Branch 5, Davao City, and in the Regional Trial Court, Branches 12 and 15, Davao City.

FACTS

A 1999 judicial audit of several courts in Davao City revealed that Civil Case No. 20394, pending before RTC Branch 15 and submitted for decision in December 1998, remained undecided due to missing transcripts of stenographic notes. Among the stenographers cited for failure to transcribe was Sarah Dujali of RTC Branch 14, who had taken notes for a hearing on March 8, 1991. The Court directed her to explain her inaction.
In her explanation, Dujali stated that the case was originally filed in RTC Branch 14, where she worked. Due to a potential conflict of interest, an assisting judge ordered the case transferred to RTC Branch 15 in March 1995. Dujali claimed she had no knowledge of the proceedings after the transfer but complied when Judge Quitain of Branch 15 later directed her to transcribe the notes, which she completed in September 1999.

ISSUE

Whether Court Stenographer Sarah Dujali is administratively liable for her failure to transcribe her stenographic notes within the period mandated by court rules.

RULING

Yes, Dujali is administratively liable. The Court found her explanation unpersuasive. Administrative Circular No. 24-90, effective August 1, 1990, unequivocally requires stenographers to transcribe their notes and attach the transcripts to the case records within twenty (20) days from the date the notes are taken. Dujali took the notes on March 8, 1991, making her deadline for transcription March 28, 1991.
Her duty to transcribe within this period was personal, direct, and non-delegable. The subsequent transfer of the case to another branch in 1995 and any later orders from a different judge did not excuse her initial and prolonged failure to comply with the 20-day rule, as these events occurred years after her deadline had already lapsed. Her eventual compliance in 1999, only after being called to account, did not absolve her of the violation. The Court imposed a fine of One Thousand Pesos (P1,000.00) with a stern warning.