Proceeding from the earlier premise that if all the
mandatory and directory periods for the resolution
of cases were followed, OFW money claims cases
should take no more than four (4) years to be
resolved from the date of filing of the complaint
before the NLRC up to the date of decision by the
Supreme Court. The foregoing data reveal that this
is not the case as it took, on the average, 7.2 years
for an OFW money claims case to go through the
entire judicial process in the period 2015-2019.
What can be sufficiently
established in this study
is the fact that in the
period 2015-2019, it took
7.2 years on the average
for an OFW money claims
case to go through the
entire judicial process…
What can be sufficiently established in this study is the fact that in the period 20152019, it took 7.2 years on the average for an OFW money claims case to go through the
entire judicial process from the date of filing of the complaint in the NLRC up to the date of
decision by the Supreme Court. It goes without saying that there were OFW money claims
cases that went through the entire judicial process in less than 7.2 years. Equally true is the
fact that there were also OFW money claims cases that took more than 7.2 years to be
resolved with finality.
Section 15(1) of Article VIII of the 1987 Constitution prescribes that “(a)ll 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.” A complaint based on this edict was however repudiated by the Supreme
Court by arguing that the time limits are only directory, and that the quality of decisions
could, at times, justifiably outweigh any intent to comply with the stipulated timelines. In the
case of “Re: Complaint-Affidavit of Elvira N. Enalbes, Rebecca H. Angeles and Estelita B.
Ocampo against Former Chief Justice Teresita J. Leonardo-De Castro [Ret.], relative to
G.R. Nos. 203063 and 204743.”46 wherein an administrative complaint was filed against
former Chief Justice Leonardo-De Castro due to her alleged failure to resolve for more than
five (5) years, two (2) related petitions assigned to the First Division of the Supreme Court,
the En Banc Resolution dismissed such complaint. The Supreme Court, speaking through the
Supreme Court ponente, Justice Marvic F. Leonen, explained:
“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.
46
A. M. No. 18-11-09-SC, January 22, 2019
25
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