SECTION 15. (1) All cases or matters filed after the effectivity of this Constitution must be decided or resolved within twenty-four months from date of submission for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts.


Re: Complaint-affidavit of Elvira N. Enalbes v. Former Chief Justice De Castro
AM 18-11-09-SC, Jan. 22, 2019


Facts: 

Complainants Enalbes, Angeles and Ocampo filed a Complaint-Affidavit against former Chief Justice Teresita J. Leonardo-De Castro, charging her with gross ignorance of the law. Complainants aver that despite the lapse of more than five (5) years, the chief justice failed to decide on the petitions of Spouses Mallari, which was raffled to her, resulting in the violation of the spouses' constitutional right to speedy disposition of their cases.


Issue:

Whether Article VIII, Section 15 of the 1987 Constitution is mandatory.


Held:

The established rule is that "constitutional provisions are to be construed as mandatory, unless by express provision or by necessary implication, a different intention is manifest." "The difference between a mandatory and a directory provision is often determined on grounds of expediency, the reason being that less injury results to the general public by disregarding than by enforcing the letter of the law.

Article VIII, Section 15 of the 1987 Constitution is merely directory and failure to decide on time would not deprive the corresponding courts of jurisdiction or render their decisions invalid.

Being the court of last resort, this Court should be given an ample amount of time to deliberate on cases pending before it.

Ineluctably, leeway must be given to magistrates for them to thoroughly review and reflect on the cases assigned to them. This Court notes that all matters brought before it involves rights which are legally demandable and enforceable. It would be at the height of injustice if cases were hastily decided on at the risk of erroneously dispensing justice.

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.

Magistrates must be given discretion to defer the disposition of certain cases to make way for other equally important matters in this Court's agenda.

As a final note, the prescribed time limit should not be ignored as to render nugatory the spirit which breathes life to the letter of the 1987 Constitution. Ultimately, courts must strike an objective and reasonable balance in disposing cases promptly, while maintaining judicious tenacity in interpreting and applying the law.

Accordingly, the failure of the former chief justice to promptly resolve the Mallari Spouses' petitions does not constitute gross ignorance of the law warranting administrative liability.