The Supreme Court in Antimaro v. Amores (A.M. No. P-05-2074) addressed the administrative liability of a court stenographer for failing to transcribe stenographic notes within the prescribed period. The Court emphasized the importance of timely transcription to ensure the prompt administration of justice. By imposing a fine, the Court underscored the necessity for court personnel to fulfill their duties efficiently and without undue delay, thereby safeguarding the rights of litigants to have their cases resolved expeditiously. This ruling serves as a reminder to all court employees about the significance of their roles in the judicial process.

Delayed Justice: When a Stenographer’s Delay Impacts Legal Recourse

This case arose from a verified complaint filed against Roslyn P. Amores, a court stenographer at the Regional Trial Court (RTC) of Butuan City. The complainants, who were defendants in a civil case, alleged that Amores failed to timely transcribe her stenographic notes (TSN) from a crucial hearing. They contended that her delay hindered their ability to file a petition for certiorari with the Court of Appeals. The heart of the issue lies in whether Amores’ delay constituted gross neglect of duty, inefficiency, or conduct prejudicial to the best interest of the service, as well as violations of Republic Act 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees.

The complainants detailed their attempts to obtain a certified true copy of the TSN following a December 23, 2003 hearing. They stated that Amores repeatedly cited her workload and the need for Judge Maclang’s approval as reasons for the delay. The complainants even sent a formal letter requesting the TSN, but their requests remained unfulfilled. Amores allegedly told them that she was busy and would provide the TSN on March 15, 2004, which prompted the complainants to file an administrative complaint.

In her defense, Amores explained that she volunteered to take notes during the December 23 hearing despite it being the office Christmas party and not her assigned duty. She acknowledged the complainants’ requests but claimed she was unable to transcribe the notes immediately due to their length and her other responsibilities. Amores also alleged that she was not the stenographer on duty for subsequent hearings and that the complainants’ persistent requests became harassing. She asserted that Judge Maclang advised her to prioritize typing court decisions and resolutions over transcribing the TSN, and that she eventually provided the TSN to the complainants on February 17, 2004, a claim the complainants denied.

The Office of the Court Administrator (OCA) recommended that Amores be fined for dereliction of duty. The Supreme Court considered Administrative Circular No. 24-90, which mandates that stenographers transcribe their notes and attach them to the case record within twenty days. The Court acknowledged Amores’ justifications, such as her other duties and the volume of notes, but emphasized that these were not compelling enough to excuse her failure to comply with the prescribed period. The Court cited jurisprudence to underscore that such excuses should not be used to escape punishment and prejudice public service. The Supreme Court ultimately found Amores guilty of simple neglect of duty and fined her P1,000.00, with a warning against future misconduct.

The Supreme Court relied on Administrative Circular No. 24-90, which clearly states the timeline for transcription. According to the circular, stenographers are required:

to transcribe all stenographic notes and to attach the transcripts to the record of the case not later than twenty (20) days from the time the notes are taken.

The Court’s decision underscores the importance of adhering to these timelines to ensure the smooth and efficient administration of justice. This administrative circular serves as a clear guideline for court stenographers and reinforces their duty to prioritize transcription and timely submission of notes.

The implications of this ruling extend beyond the specific case. By emphasizing the importance of timely transcription, the Supreme Court reinforces the principle that delays in administrative tasks can have significant repercussions on the judicial process. Litigants rely on accurate and timely records to pursue their cases, and any impediment to accessing these records can undermine their right to a fair and speedy trial. The Court also acknowledged Amores’ justifications, such as her workload and the prioritization of court decisions, but ultimately found that these factors did not excuse her failure to comply with the prescribed period.

This case serves as a reminder that while the Court is mindful of the challenges faced by court personnel, it will not compromise on the standards of efficiency and diligence required to maintain public trust in the judiciary. The penalty imposed on Amores, though relatively minor, sends a clear message that dereliction of duty will not be tolerated and that court employees must be held accountable for their actions. The Court’s decision also reflects a broader commitment to promoting ethical conduct and professionalism within the judiciary. By upholding the standards set forth in Republic Act 6713 and other relevant regulations, the Court seeks to ensure that public officials and employees perform their duties with integrity and dedication.

FAQs

What was the key issue in this case?	The key issue was whether a court stenographer’s failure to timely transcribe stenographic notes constituted neglect of duty. The case examined the stenographer’s administrative liability for delays in transcription.
What is the prescribed period for transcribing stenographic notes?	Administrative Circular No. 24-90 requires court stenographers to transcribe stenographic notes and attach them to the case record within twenty days from the date the notes were taken.
What justifications did the stenographer offer for the delay?	The stenographer cited her heavy workload, the need to prioritize court decisions, and the volume of notes as reasons for the delay in transcribing the stenographic notes.
What was the Supreme Court’s ruling?	The Supreme Court found the stenographer guilty of simple neglect of duty and fined her P1,000.00, with a warning against future misconduct.
What is the significance of Administrative Circular No. 24-90?	Administrative Circular No. 24-90 sets the standard for the timely transcription of stenographic notes, ensuring that court records are promptly available for litigants and the court.
Why did the Court not accept the stenographer’s justifications?	The Court found that the justifications offered were not compelling enough to excuse the stenographer’s failure to comply with the prescribed period, as timely transcription is crucial for the administration of justice.
What is the role of a court stenographer in legal proceedings?	A court stenographer is responsible for accurately recording the proceedings of court hearings and transcribing these records into written form.
How does this case affect the rights of litigants?	This case reinforces the importance of timely access to court records, which is essential for litigants to pursue their cases effectively and exercise their right to a fair and speedy trial.

In conclusion, the Supreme Court’s decision in Antimaro v. Amores serves as a vital reminder of the importance of efficiency and diligence in the judicial process. By holding court personnel accountable for delays in administrative tasks, the Court underscores its commitment to upholding the rights of litigants and ensuring the prompt administration of justice. This case sets a precedent for maintaining standards of conduct within the judiciary and emphasizes the responsibility of every court employee to perform their duties with integrity and dedication.

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: PABLO ANTIMARO, DINDA ANTIMARO, ANITA ODLIME, VIRGENCITA DESIATA, ESTER NADERA, JUDITH GERMAN, LITO ANTIMARO AND QUIRILICO ANTIMARO, COMPLAINANTS, VS. ROSLYN P. AMORES, COURT STENOGRAPHER, REGIONAL TRIAL COURT, BRANCH 3, BUTUAN CITY, RESPONDENT., G.R No. 43978, September 16, 2005