G.R. No. L-40884. August 22, 1978. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO DE LEON, ET AL., accused, ROMEO CHAVEZ, accused-appellant. In re Loss of Stenographic Notes, BERNARDINO B. BLANCAFLOR, stenographer, respondent.
FACTS

This administrative matter arose from the criminal case against Roberto De Leon, et al. The Supreme Court required respondent Bernardino B. Blancaflor, a former temporary stenographer of the Court of First Instance of Rizal, Pasay City Branch, to submit his transcript of the stenographic notes for a hearing dated October 20, 1973, and to show cause why no disciplinary action should be taken for his prior failure to submit them. Blancaflor failed to comply, leading the Court to impose a P200 fine. He later moved to lift the fine, claiming the notes might have been lost when his residence burned in December 1974, and suggested retaking the testimony.
The matter was referred for investigation to the Executive Judge of the Pasay court. Blancaflor did not comply with the judge’s directive to appear or submit an affidavit. The investigation found he violated Section 17, Rule 136 of the Rules of Court, which requires stenographers to deliver their notes to the clerk of court immediately after each session. He also failed to comment on the investigative report when required by the Supreme Court. At the time of the resolution, Blancaflor was serving as a temporary stenographer in Kidapawan.

ISSUE

Whether respondent stenographer Bernardino B. Blancaflor should be held administratively liable for the loss of his stenographic notes and for violating court rules and directives.

RULING

Yes, the Supreme Court found Blancaflor administratively liable. The legal logic is anchored on the mandatory duty of court stenographers under Section 17, Rule 136 to safeguard and promptly submit their notes. This duty is crucial for the integrity of judicial records and the appellate process. Blancaflor’s failure to deliver the notes immediately after the session constituted a prima facie violation. His excuse of a fire was deemed insufficient, especially given his non-compliance with the investigative directives, which demonstrated a lack of diligence and respect for judicial processes. The Court emphasized that such negligence undermines the administration of justice, as lost notes can necessitate retrials, causing delay and prejudice.
The P200 fine previously imposed was sustained. Furthermore, due to this incident and a documented pattern of inefficiency in submitting transcripts in other cases, the Court severely censured Blancaflor and ordered that his temporary appointment not be renewed upon its expiration. This additional sanction reflects the principle that repeated negligence warrants more severe administrative consequences to uphold the standards of the judiciary. The ruling serves to enforce accountability among court personnel, ensuring the proper preservation of court records essential for justice.