N. Rights to Speedy Trial and Speedy Disposition of Cases

Sin Perjuico Judgments

One that is rendered without a statement of the facts in support of its conclusions, to be later supplemented by the final judgment. The Supreme Court expressed its disapproval of the practice of rendering of sin perjuicio judgments. (NACHURA)

Timeframe for Deciding (PHIL. CONST., art. VIII, § 15.)

The periods above commence from the date of submission for decision or resolution.

A case or matter shall be 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.

Upon expiration of the period without decision or resolution, a certification stating why no decision or resolution has been rendered shall be issued and signed by the Chief Justice or presiding judge. A copy of the certification shall be attached to the record of the case or matter, and served upon the parties. The certification shall state why a decision or resolution has not been rendered or issued within said period.

The expiration of the period notwithstanding, the court shall decide or resolve the case or matter without further delay.

Being the court of last resort, the Supreme Court should be given an ample amount of time to deliberate on cases pending before it. While the 24- month period provided under the 1987 Constitution is persuasive, it does not summarily bind this Court to the disposition of cases brought before it. It is a mere directive to ensure this Court's prompt resolution of cases, and should not be interpreted as an inflexible rule. (Re: Elvira N. Enalbes, A.M. No. 18-11-09-SC (Resolution, Jan. 22, 2019)

The Sandiganbayan falls under the 12-month period applicable to lower collegiate courts (Re: Problems of Delays in Cases Before the Sandiganbayan, A.M. No. 00- 8-05-SC, Jan. 31, 2002).

A judge who fails to resolve cases within the period prescribed may be held liable for gross inefficiency, unless he explains his predicament and asked for extensions of time from the Supreme Court. (OCA v. Quiñanola, A.M. No. MTJ-99-1216, Oct. 20, 1999)