The Supreme Court in this case emphasizes the importance of efficiency and timely performance of duties by court personnel. Court Stenographer Edgardo Y. Bacatan was found guilty of simple neglect of duty for failing to transcribe stenographic notes within the prescribed period, violating Administrative Circular No. 24-90. The Court underscored that delays in transcribing notes undermine public trust and impede the administration of justice, and it thus handed down a two-month suspension. This ruling serves as a reminder of the judiciary’s commitment to promptness and diligence in fulfilling its responsibilities to the public.

Justice Delayed: When a Court Stenographer’s Neglect Undermines Legal Proceedings

In SPO2 Jonathan M. Alcover Sr. v. Edgardo Y. Bacatan, the Supreme Court addressed the administrative liability of a court stenographer who failed to transcribe stenographic notes within the time frame mandated by Administrative Circular No. 24-90. The case originated from a complaint filed by SPO2 Jonathan M. Alcover Sr., who was convicted of murder in Criminal Case No. CBU-55699. Alcover alleged that Court Stenographer III Edgardo Y. Bacatan deliberately delayed the release of the transcript of stenographic notes (TSN), particularly the testimony of witness Christian Paras, taken on September 18, 2001, hindering Alcover’s defense.

The Office of the Court Administrator (OCA) investigated the complaint and found that Bacatan indeed took almost three years to transcribe the testimony of Christian Paras. Bacatan, in his defense, cited heavy workload as the reason for the delay. He also argued that the complainant did not show interest in claiming the transcripts during the trial and only requested the complete transcript after conviction for purposes of appeal. The OCA, however, found these justifications inadequate and recommended that Bacatan be held administratively liable for simple neglect of duty.

The Supreme Court affirmed the OCA’s recommendation, emphasizing the crucial role of judicial officers and employees in upholding public trust through efficient and effective service. Administrative Circular No. 24-90 explicitly requires stenographers to transcribe notes within twenty days from the date they are taken. This directive is to ensure that court records are kept updated to allow all parties, especially the litigants, access to information when needed for the dispensation of justice. The Court, in finding Bacatan liable, reinforced the stringent requirements for those involved in judicial administration.

The Court also rejected the respondent’s claim of a heavy workload, noting that such claims are unacceptable excuses for failing to perform one’s duties.

“Otherwise, every government employee charged with negligence and dereliction of duty would resort to the same convenient excuse to evade punishment, to the great prejudice of public service.”

The Supreme Court gave emphasis on the need to balance all duties to uphold public service and speedy justice. Additionally, the Court highlighted that the responsibility to transcribe notes within the prescribed period exists independently of any demands from the parties involved.

The Court further addressed the complainant’s allegation that the delay was intentional and malicious and that Bacatan wanted to tamper with the records. While emphasizing the presumption of regularity in the performance of official duties, the Court acknowledged that the delay prejudiced public service and undermined the administration of justice. However, the Court found no substantial evidence to support the claim of intentional tampering and dismissed the charge. The lack of evidence on the matter was essential in ruling out any findings of malicious intent on Bacatan’s part.

Ultimately, the Supreme Court found Bacatan guilty of simple neglect of duty, which is defined as the failure to give proper attention to tasks expected of an employee, signifying carelessness or indifference. Considering Bacatan’s prior reprimand for habitual tardiness, the Court suspended him for two months without pay, with a warning that any future similar actions would result in more severe penalties. The ruling reinforces the importance of adhering to administrative regulations to maintain efficiency and integrity in the judicial system. By imposing a concrete penalty, the Supreme Court demonstrated its commitment to upholding standards and deterring future negligence.

FAQs

What was the key issue in this case?	The key issue was whether the court stenographer should be held administratively liable for failing to transcribe stenographic notes within the period prescribed by Administrative Circular No. 24-90.
What is Administrative Circular No. 24-90?	Administrative Circular No. 24-90 requires all court stenographers to transcribe stenographic notes within twenty (20) days from the date the notes were taken and attach the transcripts to the record of the case.
What was the respondent’s defense?	The respondent claimed his heavy workload and the complainant’s failure to request transcripts during the trial contributed to the delay. He also denied intentionally tampering with the transcripts.
What is simple neglect of duty?	Simple neglect of duty is defined as a disregard of or failure to give proper attention to a task expected of an employee, signifying carelessness or indifference.
What penalty was imposed on the respondent?	The respondent was suspended from office for two (2) months without pay, with a stern warning against future similar acts.
Was the respondent’s claim of a heavy workload considered a valid excuse?	No, the Court did not consider the respondent’s heavy workload as a valid excuse, stating that it cannot justify the failure to perform his duties.
What was the basis for the complainant’s allegation of malicious delay?	The complainant alleged that the delay was intentional to prevent him from strengthening his defense, but the Court found no substantial evidence to support this claim.
What is the significance of this ruling?	This ruling underscores the importance of efficiency and adherence to administrative regulations by court personnel to ensure the speedy and orderly administration of justice.

This case serves as an important reminder to all court personnel regarding their duties and responsibilities in ensuring the prompt and efficient administration of justice. The Supreme Court’s decision highlights the significance of timely compliance with administrative regulations, and any deviations will lead to administrative liability.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SPO2 Jonathan M. Alcover Sr. v. Edgardo Y. Bacatan, A.M. No. P-05-2043, December 07, 2005